Technology and Performance Audit and Management Review of ... · Technology and Performance Audit and Management Review of the Federal Election Commission Volume II – Appendixes

Technology and Performance Auditand Management Review of the

Federal Election Commission

Volume II – Appendixes

January 29, 1999

Prepared by PricewaterhouseCoopers LLP

1616 North Fort Myer Drive

Arlington, Virginia 22209

This report in its entirety is posted on the Internet atwww.gao.gov/special.pubs/publist.htm

Management Review of the Federal Election Commission

PricewaterhouseCoopers LLP TOC− 1

Volume II: Appendixes

PAGE

Table of Contents… … … … … … … … … … … … … … … … … … … … … … … … … … … TOC− 1

Appendix A: FEC Organizational Chart

Office of the Commissioners… … … … … … … … … … … … … … A− 1

Office of the Staff Directors… … … … … … … … … … … … … … .. A− 2

Office of the General Counsel… … … … … … … … … … … … … .. A− 3

Appendix B: FEC “Regulated” Customer Satisfaction Survey and Tabulation

Survey Methodology and Summary… … … … … … … … … … … . B− 1

Overall Assessment of the FEC… … … … … … … … … … … … … . B− 3

Composition of the Sample… … … … … … … … … … … … … … ... B− 3

Analysis of 51 Questions

Appendix C: FEC Program Process Maps and Narratives

1.0 Public Disclosure Division … … … … … … … … … … … … … .. C1− 1

1.1 Processing Campaign Finance Reports (FEC and Senate)... C1− 1

1.1.1 Receiving Campaign Finance Reports… … … … … … . C1− 2

1.1.2 Preparing Documents… … … … … … … … … … … … … C1− 2

1.1.3 Scanning and Filming Documents… … … … … … … .. C1− 3

1.1.4 Post-Processing Documents… … … … … … … … … … . C1− 3

1.2 Processing Agency Documents… … … … … … … … … … … .. C1− 3

1.2.1 Placing a MUR on the Public Record… … … … … … . C1− 4

1.3 Processing Internal Documents… … … … … … … … … … … C1− 4


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1.4 Responding to Information Requests… … … … … … … … … . C1− 4

Process Maps

2.0 Data Systems Division… … … … … … … … … … … … … … … … ... C2− 1

2.1 Processing of Campaign Finance Reports (Manual andElectronic)… … … … … … … … … … … … … … … … … … … ...

C2− 1

2.1.1. Logging and Sorting… … … … … … … … … … … … … C2− 1

2.1.2 Conducting Pass 1 Coding… … … … … … … … … … .. C2− 2

2.1.3 Conducting Pass 1 Data Entry… … … … … … … … … C2− 2

2.1.4 Conducting Pass 1 Data Entry/Verification… … … ... C2− 3

2.1.5 Conducting Pass 3 Coding… … … … … … … … … … .. C2− 3

2.1.6 Conducting Pass 3 Data Entry/ Verification… … … .. C2− 4

Process Maps

3.0 Reports Analysis Division… … … … … … … … … … … … … … … .. C3− 1

3.1 Processing Campaign Finance Documents… … … … … … … C3− 1

3.1.1 Reviewing and Analyzing Reports… … … … … … … … C3− 1

3.1.2 Updating Status Report and Re-filing Original… … … C3− 2

3.2 Processing Requests for Additional Information (RFAIs)… ... C3− 3

3.3 Processing Non-Filer Notices… … … … … … … … … … … … .. C3− 3

3.4 Processing Debt Settlements… … … … … … … … … … … … … C3− 3

3.5 Processing Administration Terminations… … … … … … … … C3− 4

Process Maps

4.0 Audit Division… … … … … … … … … … … … … … … … … … … … . C4− 1

4.1 Audits-For-Cause… … … … … … … … … … … … … … … … … .. C4− 1

4.1.1 Preparing for Commission Vote and NotifyingCandidates/Committees… … … … … … … … … … … … ..

C4− 1

4.1.2 Conducting Pre-Audit… … … … … … … … … … … … … . C4− 2


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4.1.3 Conducting Fieldwork… … … … … … … … … … … … … C4− 2

4.1.4 Conduct Post-Audit and Processing Audit Report… ... C4− 3

4.2 Audit-For-Cause – Referral (437(g))… … … … … … … … … … . C4− 4

4.2.1 Receiving Referral… … … … … … … … … … … … … … ... C4− 4

4.2.2 Conducting Pre-Audit… … … … … … … … … … … … … . C4− 5

4.2.3 Conducting Fieldwork… … … … … … … … … … … … … C4− 5

4.2.4 Conducting Post-Audit and Processing Audit Report.. C4− 6

4.3 Presidential Public Funding Program… … … … … … … … … .. C4− 6

4.3.1 Certifying Presidential Public Funding… … … … … … . C4− 6

4.3.2 Conducting Title 26 Audits… … … … … … … … … … … C4− 8

Process Maps

5.0 Office of General Counsel… … … … … … … … … … … … … … … . C5− 1

5.1 Public Financing, Ethics and Special Projects… … … … … … C5− 1

5.1.1 Prosecuting Violations… … … … … … … … … … … … … C5− 1

5.1.2 Conducting Legal Review of Public Financing… … … C5− 1

5.1.2.1 Reviewing Eligibility for Matching Funds… … C5− 1

5.1.2.2 Reviewing Entitlement Recommendations… .. C5− 2

5.1.2.3 Conducting Legal Review of Audit Reports… C5− 3

5.1.2.4 Reviewing Repayment Recommendation… ... C5− 3

5.2 Policy Division… … … … … … … … … … … … … … … … … … .. C5− 4

5.2.1 Rendering Advisory Opinions… … … … … … … … … … C5− 4

5.2.1.1 Reconsideration… … … … … … … … … … … … . C5-4

5.2.2 Reviewing Regulations… … … … … … … … … … … … ... C5− 5

5.2.3 Conducting Legal Review of Federal ElectionCommission Act… … … … … … … … … … … … … … … .. C5− 6


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5.3 Enforcement Division… … … … … … … … … … … … … … … ... C5− 6

5.3.1 Enforcement… … … … … … … … … … … … … … … … … . C5− 6

5.3.2 Central Enforcement Docket… … … … … … … … … … .. C5− 6

5.3.3 Statements of Reason… … … … … … … … … … … … … .. C5− 8

5.3.4 Dismissing Low Rating and StaleCases… … … … … … … … . C5− 8

5.3.5 Maintaining the Permanent File… … … … … … … … … C5− 8

5.3.6 Coordinating Executive Session Agenda… … … … … .. C5− 8

5.3.7 Tracking Civil Penalties… … … … … … … … … … … … .. C5− 8

5.3.8 Archiving… … … … … … … … … … … … … … … … … … .. C5− 9

5.4 Litigation Division… … … … … … … … … … … … … … … … … . C5− 9

Process Maps

6.0 Office of Planning and Management… … … … … … … … … … … C6− 1

6.1 Budget Formulation… … … … … … … … … … … … … … … … .. C6− 1

6.2 Budget Management… … … … … … … … … … … … … … … … . C6− 2

6.3 Monthly Budget Reporting… … … … … … … … … … … … … ... C6− 3

6.4 Developing FY2000 Performance Plan… … … … … … … … .. C6− 3

Process Maps

7.0 Administration Division… … … … … … … … … … … … … … … … . C7− 1

7.1 Accounts Payable… … … … … … … … … … … … … … … … … . C7− 1

7.2 Procurement… … … … … … … … … … … … … … … … … … … .. C7− 1

7.3 Vouchering… … … … … … … … … … … … … … … … … … … … C7− 1

7.4 Monthly Reconciliation… … … … … … … … … … … … … … … C7− 2

7.5 Cash Receipt System… … … … … … … … … … … … … … … … . C7− 2

Process Maps

Appendix A

FEC Organization Chart

Office of CommissionerDavid M. Mason

Member EL-IV

Special Assistant GS-13

Office of CommissionerScott E. Thomas

Member EL-IVExecutive Assistant GS-15Special Assistant GS-13

Office of CommissionerLee Ann Elliott

Member EL-IV

Executive Assistant GS-15


Office of CommissionerKarl J. Sandstrom

Member EL-IV


Office of CommissionerDarryl R. Wold

Member EL-IV

Office of CommissionerDanny L. McDonald

Member EL-IV



Office of the General Counsel

[See Office of the General Counsel Organization]

[See Office of the Staff Director Organization]

Office of the Staff Director

Inspector General GS-15

(2x) Auditor GS-13


Office of the Inspector General


Office of the Commissioners

Note: Only full-time permanent positions identified.

Source: FEC Staffing Report, September 25,1998 Appendix A-1


Office of the Staff DirectorCommissioners

Office of the Staff DirectorActing Staff Director EL-IV

Congressional Affairs Officer GS-14�Asst. to Congressional Affairs Officer GS-13�Spec Asst. to the Dep. Staff Director GS-11

Admin. Assistant GS-9�Admin. Asst. (Typing) GS-7�Admin. Clerk (Typing) GS-7

Secretary to the Commission

Secretary GS-14�Spec. Asst. to the Secretary GS-13�

Deputy Secretary GS-12�Admin. Assistant (Typing) GS-9�

Admin. Clerk (Typing) GS-7

Press Office

Press Officer GS-15�Deputy Press Officer GS-14�Public Affairs Spec. GS-12�Public Affairs Spec. GS-11�

Admin. Secretary (Typing) GS-7

EEO Office

Director, EEO & Special Pgrms. GS-14

Office of Personnel

(2x) Asst. Director of Personnel GS-13�Personnel Asst. (Typing) GS-9�

Clerk GS-3

Election Administration

Director of Clearinghouse GS-15�Deputy Director GS-14�

(2x) Research Specialist GS-13Public Affairs Specialist GS-11

Planning and Management

Director, Planning and Mgmt. GS-15�Program Analyst GS-12

Administrative Division

Administrative Officer GS-14�Printing Officer GS-12�

Admin. Special Assistant GS-11�Management Assistant GS-8�

General Supply Specialist GS-6

Audit Division

Asst. Staff Director GS-15�Deputy Asst. Staff Dir. (PECF) GS-14

Deputy Assistant Deputy AssistantDeputy Asst. Staff

Dir. for Audit GS-14

Deputy Asst. Staff

Dir. for Audit GS-14

Information Division

Asst. Staff Director GS-15Admin. Asst. GS-9

Director of Data Systems GS-15�Secretary/Receptionist(Typing) GS-5

Data Systems Development

Asst. Staff Director GS-15�Dep. Asst. Staff Dir. Disclosure GS-12

Disclosure DivisionOffice Services Branch

Support Services Supervisor GS-8�Management Assistant GS-7�

Duplicating Equip. Operator GS-7�Mail Clerk GS-6�

(3x) Administrative Aide GS-6

Payroll and Accounting

Accounting Officer GS-14�Asst. Accounting Officer GS-13�

Systems Accountant GS-12�(2x) Accounting Technician GS-9�Disbursement Technician GS-9

Accounting Technician GS-8

Audit Team 1

Audit Manager GS-13�(2x) Auditor GS-13�

Auditor GS-12�

Audit Team 2

Audit Manager GS-13�(3x) Auditor GS-12

Auditor GS-11�

Audit Team 3

(2x) Auditor GS-12(2x) Auditor GS-11

Audit Team 4

Audit Manager GS-13�Auditor GS-13�

(2x) Auditor GS-12�Auditor GS-9

Audit Team 5

Audit Manager GS-13�Auditor GS-12�Auditor GS-11

Audit Team 6

Audit Manager GS-13�Auditor GS-11�

(2x) Auditor GS-9Auditor GS-7

Information Services Staff

Deputy Asst. Staff Dir. GS-14�Senior Public Affairs Spec. GS-13�Senior Public Affairs Spec. GS-12�

(2x) Public Affairs Spec. GS-11�(2x) Tech. Manual Writer/Editor GS-11�

Public Affairs Spec. GS-9�Management Asst. (Typing) GS-7

Reports Analysis Division

Asst. Staff Director GS-15Deputy Asst. Staff Dir., R.A. GS-14

Management Asst. GS-7Secretary (typing) GS-6Secretary (typing) GS-5

Non Party/Party Branch

Chief, Non Party/Party Branch GS-13

(3x) Sr. Reports Analyst GS-11(4x) Reports Analyst GS-9(2x) Reports Analyst GS-7(5x) Reports Analyst GS-5

Authorized Committee Branch

Chief, Authorized Committee Branch GS-13�

Senior Reports Analyst GS-11�(5x) Reports Analyst GS-9(4x) Reports Analyst GS-7(2x) Reports Analyst GS-5

File Room

(2x) File Clerk GS-5�(2x) Records Clerk

(Typing) GS-3

Compliance Branch

Chief, Compliance Branch GS-13Sr. Compliance Analyst GS-11�

Compliance Analyst GS-7Compliance Assist. GS-5Compliance Analyst GS-5

Public Records Branch

Dep. Asst. Staff Dir. GS-12�(2x) Public Info. Clerk GS-7�(2x) Public Info. Clerk GS-6

Public Info. Clerk GS-5�File Clerk GS-4

Processing Branch

Dep. Asst. Staff Dir. GS-12�Sr. Data Processing Clerk GS-7�

(2x) Data Processing Clerk GS-5

Development

Computer Sys. Analyst (Supv.) GS-14(5x) Computer Programmer GS-12Computer Spec./Instructor GS-12

Computer Programmer GS-11

SystemsSupv. Computer Sys. Anal. GS-14�

Computer Spec. GS-13�Computer Programmer GS-12�

Management Analyst GS-11�Computer Programmer GS-9

Management Asst. GS-9�

Data Entry Staff

Chief of Data Entry GS-9�(4x) Data Entry Clerk GS-5

Analysis

Supv. Statistician GS-14�Computer Programmer GS-12�

Statistician GS-11�Management Analyst GS-11

Branch Manager GS-13�(3x) Sr. Disclosure Data Spec. GS-8�

(7x) Disclosure Data Spec. GS-7�(2x) Disclosure Data Spec. GS-6

Data Coding

Supv. Computer Spec. GS-14�(4x) Computer Spec./Instructor GS-12

User Support Spec. GS-11�Computer Spec./User Support GS-9

Training/Customer Support


Source: FEC Staffing Report, September 25,1998 Appendix A-2

Commissioners

Office of The General CounselGeneral Counsel EL-V�

Special Asst. to General Counsel GS-13Legal Info. System Manager GS-13

Management Assistant GS-11�Exec. Sec. to the General Counsel GS-11�

Administrative Asst. (typing) GS-7�Admin. Clerk (typing) GS-5

Assoc. General Counselfor Public Financing, Ethics,

and Special ProjectsAssoc. General Counsel SL-0�

Special Assistant GS-12�Executive Secretary GS-9�

Administrative Asst.(Typing) GS-7

Team IAsst. General Counsel GS-15

(4x) Attorney GS-14�Paralegal Specialist GS-11�

Team IIAsst. General Counsel GS-15

(4x) Attorney GS-14�Paralegal Specialist GS-9

PFESP DocketSpecial Asst. GC GS-15�

Paralegal Specialist GS-11Paralegal Specialist GS-9

Enforcement Team IAsst. General Counsel GS-15

(2x) Attorney GS-14�(3x) Attorney GS-13�

Law Clerk GS-11�(2x) Paralegal Specialist GS-11

Legal Intern GS-7Legal Secretary (Typing) GS-7

Enforcement Team IIAsst. General Council Enforcement

GS-15�(2x) Attorney GS-14�(2x) Attorney GS-13

Attorney GS-12�Law Clerk GS-11�

(2x) Paralegal Specialist GS-9Legal Secretary (Typing) GS-7

Enforcement Team IIIAsst. Gen Counsel GS-15�

(3x) Attorney GS-14�Attorney GS-13�

(2x) Paralegal Specialist GS-11Legal Secretary (Typing) GS-7

Asst. Gen Counsel GS-15�(5x) Attorney GS-14�

Attorney GS-12�(2x) Paralegal Specialist GS-11Legal Secretary (Typing) GS-7

Enforcement Team IV

Central Enforcement DocketSupervisory Attorney (CED) GS-14�

Docket Manager GS-11�(2x)Paralegal Specialist GS-11�

CED Assistant GS-9Docket Assistant (typing) GS-7

Advisory Opinions and Legal Review FECA

Senior Attorney GS-14�Attorney GS-14

Legal Review - Administrative Law

Asst. General Counsel - GS-15�Attorney GS-14�

(2x) Paralegal Specialist GS-11

Regulations

Asst. General Counsel - GS-15�Senior Attorney GS-14�

(3x) Attorney GS-14Admin. Asst. GS-7

Appelate Court Litigation

(2x) Attorney GS-14

District Court LitigationAsst. General Counsel GS-15

Senior Attorney GS-14�(2x) Attorney GS-14�(3x) Attorney GS-13

Paralegal Specialist GS-11Paralegal Specialist GS-9

Legal Secretary (Typing) GS-7

Assoc. General Counselfor Enforcement

Assoc. General Counsel SL-0�(2x) Investigator GS-13Special Assistant GS-12�

Executive Secretary GS-9

Assoc. General Counselfor Policy

Assoc. General Counsel SL-0Admin. Asst. (Typing) GS-7

Assoc. General Counsel for Litigation

Assoc. General Counsel SL-0�Management Assistance GS-11�

Admin. Asst. (Typing) GS-7


Source: FEC Staffing Report, September 25,1998

Library

Library Director (Law) GS-13�Library Technician GS-9


Office of General Counsel

Appendix A-3

Appendix B

FEC “Regulated” Customer SatisfactionSurvey and Tabulation


PricewaterhouseCoopers LLP Appendix B− 1

Survey Methodology and Summary

The Federal Election Commission (FEC) CustomerSatisfaction Survey was designed to evaluate FECeffectiveness in providing information to the regulatedcommunity and in facilitating disclosure of campaignfinance information. The questionnaire focused on specificFEC products, services, and processes and was administeredby telephone to 353 randomly selected Congressionalcandidate committees, political party committees, and PACsthat filed reports with the FEC during the 1997− 1998election cycle. These committees were selected from a listof all registered committees provided by the FEC, using astratified random sample technique to assure a sufficientsample size for each major filer group. ThePricewaterhouseCoopers Survey Research Center inBethesda, Maryland, conducted the interviews duringAugust and September 1998. Each committee was notifiedof the survey through a front-page article in the August issueof The Record.

The results of the survey indicated that, overall, theregulated community is quite satisfied with the products andservices provided by the Federal Election Commission.While the level of usage of these products and servicesvaries, the degree of satisfaction is consistently positive.Moreover, surveyed filers generally perceive theCommission to be fair and nonpartisan. Details of the survey

follow this narrative. Here are the notable findings from thesurvey:

• Reporting Forms and Instructions. Four out of five (83%)believed that the instructions included with reportingforms were either “somewhat” or “very” clear. Only 7%said that they required a “great deal” of assistance infiling their FEC reporting forms, and a quarter (25%) didnot need any assistance at all.

• Reports Analysis Division (RAD) Staff. Nearly three-quarters (72%) of all surveyed filers have contacted theirassigned RAD staff person since January 1, 1997. Nineout of ten (92%) committees spending over $500,000report contacting RAD staff, while only six out of ten(60%) committees spending $50,000 or less reportcontacting their RAD staff person. On average, filerscontacted their RAD staff person once per reportingperiod.

RAD personnel were seen in positive terms. Forexample, 86% stated that the RAD staff always answer ina timely fashion, 80% agreed that RAD staff alwaysanswered questions accurately, and 67% stated thatRAD staff always are available to respond to requests.

Two-thirds (66%) of all filers report having received aRequest for Additional Information (RFAI) since January1, 1997; however, only one-half (49%) of PACs reportreceiving an RFAI. Of those who received RFAIs, four



out of five (82%) believed that the content of RFAIs iseither “somewhat” or “very” clear.

• Phone Calls to the FEC. One-half (51%) of all surveyedfilers had called the FEC for reasons other than to discusstheir reports, and, on average, they made two calls to theFEC during a reporting period. Reasons for calls to theFEC included obtaining information on laws andregulations (78%), ordering forms or publications (53%),obtaining public records about candidates or committees(25%), obtaining information about voting laws andelection statistics (11%), and obtaining other information(17%). Of those surveyed filers who had called the FEC,nearly all (96%) agreed that the FEC staff personanswered their questions accurately. Nine out of ten(92%) filers reported that their questions were answeredwithin 24 hours of the call.

• Publications. Nine out of ten (90%) surveyed filers wereaware of the FEC newsletter, The Record, and almosthalf read it every month.

Over three-quarters (76%) of sampled filers were awareof the FEC Campaign Guides. However, only two-thirdsof PACs (65%) and small committees (67%) were awareof them. Almost nine out of ten (87%) surveyed filersbelieved that the Campaign Guides were either“somewhat” or “very” clear, and two out of five (42%)said that they are “very” helpful as a resource forcompleting disclosure reports. Political party

committees, however, were less likely to view CampaignGuides as “very” helpful (19%).

• Web Site. Only four out of ten (42%) surveyed filers hadaccessed the FEC World Wide Web site. Further, onlythree out of ten (29%) small committees had accessedthe site, while six out of ten (61%) large committees had.Those filers who did access the Web site did so anaverage of two times per month. Reasons for accessingthe Web site included to find campaign finance reportsand statistics (71%), to get FEC forms and documents(55%), to obtain election results (32%), and to obtainFEC press releases (16%) and FEC publications (17%).Nine out of ten filers (91%) who have accessed the Website said that information there was either “somewhat” or“very” accessible.

• Enforcement Staff. Only 14% of surveyed filers hadever had any interaction with FEC enforcement staff. Ofthese, nearly three-quarters (73%) agreed that FECenforcement staff operated in an independent,nonpartisan manner. Less than one out of five (18%)said that the written communications from theenforcement staff were either “somewhat” or “very”unclear.

• Importance of Various Services. Among the variousservices mentioned, the RAD staff person and CampaignGuides were deemed either “somewhat” or “very”important by nine out of ten filers (93% and 92%



respectively). Over half of the surveyed filers reportedthat they had never used the automated Faxline (54%) orthe Public Records Office (52%) or that they had neverattended an FEC conference or workshop (60%).

Overall Assessment of the FEC

Surveyed filers were quite positive in their assessments of theFEC, perhaps higher that one would have expected, giventhe strength of recent criticisms leveled at the FEC. On ascale from 1 to 10, where 1 means poor and 10 meansexcellent, they gave the FEC an average rating of 8. Threeout of five rated the FEC as an 8 or higher.

In general, surveyed filers perceived the FEC to be fair andimpartial. However, large committees and political partieswere more likely to disagree that the FEC fairly appliescompliance laws (21% each) than committees as a whole(12%).

Composition of the Sample

A random, stratified sample was selected, based both on thetype of committee and the amount of financial activity, toallow for comparisons between groups as well as torepresent the population as a whole. From the 510 selectedrespondents, 353 completed interviews (69%). Thedistribution of the sampled respondents, by committee type,was Senate – 14%, House – 26%, PACs – 42%, and Party –

18%. The distribution for the amount of spending by therespondents was 22% for committees spending more than$500,000, 33% for those spending between $50,000 and$500,000, and 45% for committees spending less than$50,000.

The partisan representation in the sample was fairly evenlydivided among Republicans and Democrats. Amongcandidate committees, 50% of the candidates wereRepublican, 45% Democrat, and 4% represent anotherparty. Among political party committees, 45% wereRepublican, 42% Democrat, and 11% from other parties.

All Senate House

Yes 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

No 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77

† Results based on sample sizes of less than 25 may be too small for drawing statistical conclusions. Therefore, caution should be used when basing conclusions on these data.

Q1. Have you filed a report with the FEC since January 1, 1997?

Amount of Spending

Less than or Equal to $50,000

$50,000 - $500,000

More than $500,000

Type of Committee

Candidate Committee Political Action Committee

Political Party Committee

FEC Customer SurveyFinal Tabulations 1

PricewaterhouseCoopers Survey Research CenterOctober 15, 1998

All Senate House

One to Four 5.9% 6.0% 5.5% 5.4% 7.9% 4.4% 7.8% 6.5%

Five 7.4% 12.0% 4.4% 6.0% 11.1% 8.1% 3.4% 11.7%

Six 9.3% 12.0% 9.9% 8.7% 7.9% 10.6% 6.0% 11.7%

Seven 13.6% 12.0% 15.4% 11.4% 17.5% 13.1% 12.9% 15.6%

Eight 32.0% 24.0% 34.1% 30.9% 38.1% 30.0% 38.8% 26.0%

Nine 17.3% 22.0% 17.6% 18.8% 9.5% 18.1% 19.0% 13.0%

Ten 10.8% 10.0% 9.9% 14.1% 4.8% 10.6% 11.2% 10.4%

Don't know 3.1% 0.0% 3.3% 4.0% 3.2% 4.4% 0.9% 3.9%

Refused 0.6% 2.0% 0.0% 0.7% 0.0% 0.6% 0.0% 1.3%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Average Rating 8 7 8 8 7 8 8 7

Sample Size 353 50 91 149 63 160 116 77


Q2. On a scale from one to ten, where one means poor and ten means excellent, overall, how well do you think the FEC does its job?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very clear 34.6% 38.0% 35.2% 37.6% 23.8% 31.9% 37.1% 36.4%

Somewhat clear 48.2% 42.0% 48.4% 50.3% 47.6% 48.1% 50.0% 45.5%

Somewhat unclear 13.6% 16.0% 13.2% 7.4% 27.0% 15.0% 10.3% 15.6%

Very unclear 2.3% 2.0% 2.2% 2.7% 1.6% 3.1% 1.7% 1.3%

Neutral 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Don't know 1.4% 2.0% 1.1% 2.0% 0.0% 1.9% 0.9% 1.3%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q3. How clear would you say the instructions included with reporting forms are?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

A great deal of assistance 6.5% 4.0% 5.5% 3.4% 17.5% 6.3% 5.2% 9.1%

Some assistance 28.3% 46.0% 33.0% 18.8% 30.2% 22.5% 31.0% 36.4%

Only a little assistance 39.7% 34.0% 41.8% 43.0% 33.3% 37.5% 42.2% 40.3%

No assistance at all 24.6% 16.0% 19.8% 32.9% 19.0% 33.1% 19.8% 14.3%

Don't know 0.8% 0.0% 0.0% 2.0% 0.0% 0.6% 1.7% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q4. In filing your FEC reporting forms, do you find that you need...

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 71.7% 72.0% 81.3% 64.4% 74.6% 60.0% 74.1% 92.2%

No 27.5% 28.0% 18.7% 34.2% 23.8% 38.8% 25.0% 7.8%

Don't know 0.8% 0.0% 0.0% 1.3% 1.6% 1.3% 0.9% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q5. Have you ever contacted the staff person who reviews your reports?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Less than 1 time 14.6% 11.1% 12.2% 20.8% 8.5% 17.7% 15.1% 9.9%

1 time 58.5% 52.8% 56.8% 57.3% 68.1% 62.5% 52.3% 60.6%

2 - 3 times 19.8% 27.8% 28.4% 13.5% 12.8% 15.6% 23.3% 21.1%

More than 3 times 5.9% 8.3% 2.7% 6.3% 8.5% 3.1% 8.1% 7.0%

Don't know 0.8% 0.0% 0.0% 1.0% 2.1% 0.0% 1.2% 1.4%

Refused 0.4% 0.0% 0.0% 1.0% 0.0% 1.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Average Number of Times 1 1 1 1 2 1 1 2

Sample Size* 253 36 74 96 47 96 86 71

*Sample sizes based on those who responded 'Yes' to question 5.


Q6. On average, how many times during a reporting period do you call the staff person who reviews your reports?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Always 67.2% 69.4% 66.2% 66.7% 68.1% 62.5% 72.1% 67.6%

Sometimes 28.9% 25.0% 27.0% 30.2% 31.9% 34.4% 23.3% 28.2%

Rarely 2.0% 5.6% 4.1% 0.0% 0.0% 0.0% 2.3% 4.2%

Never 0.8% 0.0% 1.4% 1.0% 0.0% 1.0% 1.2% 0.0%

Don't know 1.2% 0.0% 1.4% 2.1% 0.0% 2.1% 1.2% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 253 36 74 96 47 96 86 71



Q7. How often is this staff person available to respond to your requests?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Always 79.8% 83.3% 81.1% 81.3% 72.3% 84.4% 81.4% 71.8%

Sometimes 15.8% 16.7% 13.5% 13.5% 23.4% 11.5% 12.8% 25.4%

Rarely 0.4% 0.0% 0.0% 1.0% 0.0% 1.0% 0.0% 0.0%

Never 0.4% 0.0% 0.0% 1.0% 0.0% 0.0% 1.2% 0.0%

Don't know 3.6% 0.0% 5.4% 3.1% 4.3% 3.1% 4.7% 2.8%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 253 36 74 96 47 96 86 71



Q8. How often does this staff person answer your questions accurately?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Always 86.2% 86.1% 86.5% 84.4% 89.4% 86.5% 84.9% 87.3%

Sometimes 11.5% 8.3% 10.8% 13.5% 10.6% 11.5% 12.8% 9.9%

Rarely 1.2% 5.6% 1.4% 0.0% 0.0% 1.0% 1.2% 1.4%

Never 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Don't know 1.2% 0.0% 1.4% 2.1% 0.0% 1.0% 1.2% 1.4%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 253 36 74 96 47 96 86 71



Q9. How often does this staff person answer your questions in a timely manner?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 66.3% 80.0% 80.2% 49.0% 76.2% 48.1% 76.7% 88.3%

No 29.7% 14.0% 16.5% 47.7% 19.0% 44.4% 23.3% 9.1%

Don't know 4.0% 6.0% 3.3% 3.4% 4.8% 7.5% 0.0% 2.6%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q10. Have you received a Request for Additional Information or RFAI since January 1, 1997?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very clear 42.7% 40.0% 42.5% 50.7% 33.3% 41.6% 50.6% 33.8%

Somewhat clear 39.3% 45.0% 34.2% 37.0% 45.8% 39.0% 36.0% 44.1%


Very unclear 4.7% 2.5% 6.8% 4.1% 4.2% 5.2% 4.5% 4.4%

Neutral 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Don't know 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 234 40 73 73 48 77 89 68



Q11. In your opinion, how clear is the content of RFAIs?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 50.7% 56.0% 56.0% 45.6% 50.8% 35.6% 61.2% 66.2%

No 49.3% 44.0% 44.0% 54.4% 49.2% 64.4% 38.8% 33.8%

Don't know 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q12. Other than to discuss your reports, have you ever called the FEC?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Less than 1 time 19.8% 7.1% 15.7% 28.8% 18.8% 28.6% 21.4% 7.8%

1 time 48.6% 53.6% 49.0% 43.9% 53.1% 42.9% 47.1% 56.9%

2 - 3 times 21.5% 28.6% 25.5% 15.2% 21.9% 19.6% 21.4% 23.5%

More than 3 times 9.6% 10.7% 9.8% 10.6% 6.3% 7.1% 10.0% 11.8%

Don't know 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Refused 0.6% 0.0% 0.0% 1.5% 0.0% 1.8% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%


Sample Size* 177 28 51 66 32 56 70 51



Q13. Other than to discuss your reports, on average, how many times during a reporting period do you call the FEC?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Obtain information on campaign finance laws and FEC regulations 77.7% 78.6% 82.4% 79.4% 65.6% 66.7% 87.3% 76.5%

Order forms or publications 52.5% 50.0% 49.0% 52.9% 59.4% 45.6% 53.5% 58.8%

Obtain public records about specific candidates or committees 24.6% 25.0% 25.5% 22.1% 28.1% 7.0% 28.2% 39.2%

Obtain information about voting and registration laws or election statistics 10.6% 10.7% 7.8% 10.3% 15.6% 8.8% 12.7% 9.8%

Other 16.8% 21.4% 19.6% 13.2% 15.6% 14.0% 15.5% 21.6%

Don't know 2.2% 0.0% 2.0% 1.5% 6.3% 5.3% 0.0% 2.0%

Refused 0.6% 0.0% 2.0% 0.0% 0.0% 0.0% 1.4% 0.0%

Total ** ** ** ** ** ** ** **

Sample Size 179* 28 51 68 32 57 71 51


**Totals may not add to 100% because respondents could select multiple answers.


Q14. Please tell me for which of the following reasons you have called the FEC since January 1, 1997.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee

Candidate Committee Political Action

Committee




All Senate House

Obtain information on campaign finance laws and FEC regulations 52.5% 57.1% 64.7% 48.5% 37.5% 49.1% 62.0% 43.1%

Order forms or publications 19.6% 17.9% 11.8% 19.1% 34.4% 21.1% 14.1% 25.5%

Obtain public records about specific candidates or committees 8.9% 3.6% 5.9% 13.2% 9.4% 7.0% 9.9% 9.8%

Obtain information about voting and registration laws or election statistics 1.1% 0.0% 0.0% 1.5% 3.1% 0.0% 1.4% 2.0%

Other 15.1% 21.4% 11.8% 14.7% 15.6% 21.1% 7.0% 19.6%

Don't know 2.2% 0.0% 3.9% 2.9% 0.0% 1.8% 4.2% 0.0%

Refused 0.6% 0.0% 2.0% 0.0% 0.0% 0.0% 1.4% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 179 28 51 68 32 57 71 51



Q15. Other than to discuss your reports, what was the reason for your most recent phone call?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee


Committee




All Senate House

Agree strongly 70.4% 64.3% 72.5% 73.5% 65.6% 73.7% 77.5% 56.9%

Agree somewhat 25.7% 32.1% 17.6% 25.0% 34.4% 21.1% 19.7% 39.2%

Disagree somewhat 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Disagree strongly 1.7% 0.0% 5.9% 0.0% 0.0% 0.0% 1.4% 3.9%

Not applicable 0.6% 3.6% 0.0% 0.0% 0.0% 1.8% 0.0% 0.0%

Don't know 1.7% 0.0% 3.9% 1.5% 0.0% 3.5% 1.4% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 179 28 51 68 32 57 71 51



Q16. Do you agree strongly, agree somewhat, disagree somewhat, or disagree strongly with the following statement: When I called, the FEC staff person answered my questions accurately.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

During the same call 54.7% 46.4% 56.9% 63.2% 40.6% 54.4% 53.5% 56.9%

Within 24 hours of your call 37.4% 46.4% 33.3% 30.9% 50.0% 33.3% 38.0% 41.2%

More than 24 hours after your call 4.5% 3.6% 7.8% 2.9% 3.1% 7.0% 4.2% 2.0%

Don't know 3.4% 3.6% 2.0% 2.9% 6.3% 5.3% 4.2% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 179 28 51 68 32 57 71 51



Q17. When you called, did the FEC staff member respond to your request...

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 90.4% 86.0% 90.1% 89.3% 96.8% 88.1% 92.2% 92.2%

No 9.3% 14.0% 8.8% 10.7% 3.2% 11.3% 7.8% 7.8%

Don't know 0.3% 0.0% 1.1% 0.0% 0.0% 0.6% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q18. Are you aware of the FEC's newsletter called The Record?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Every month 48.6% 55.8% 41.5% 52.6% 44.3% 35.5% 57.0% 62.0%

Every other month 14.1% 16.3% 15.9% 9.8% 19.7% 12.1% 18.7% 11.3%

Only a few times per year 21.0% 16.3% 20.7% 24.1% 18.0% 28.4% 13.1% 18.3%

Almost never 14.1% 11.6% 18.3% 11.3% 16.4% 21.3% 8.4% 8.5%

Don't know 2.2% 0.0% 3.7% 2.3% 1.6% 2.8% 2.8% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 319 43 82 133 61 141 107 71



Q19. On average, how often do you read The Record?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 75.9% 92.0% 84.6% 65.1% 76.2% 66.9% 81.9% 85.7%

No 22.7% 8.0% 13.2% 33.6% 22.2% 31.3% 18.1% 11.7%

Don't know 1.4% 0.0% 2.2% 1.3% 1.6% 1.9% 0.0% 2.6%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q20. Have you ever used the FEC Campaign Guide?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very clear 33.6% 30.4% 32.5% 41.2% 22.9% 29.9% 38.9% 31.8%

Somewhat clear 53.0% 56.5% 51.9% 49.5% 58.3% 54.2% 51.6% 53.0%


Very unclear 1.1% 0.0% 0.0% 1.0% 4.2% 0.9% 2.1% 0.0%

Don't know 0.7% 0.0% 1.3% 1.0% 0.0% 1.9% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 268 46 77 97 48 107 95 66



Q21. How clear would you say the Campaign Guide is?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very helpful 42.2% 47.8% 49.4% 45.4% 18.8% 41.1% 45.3% 39.4%

Somewhat helpful 48.1% 45.7% 44.2% 43.3% 66.7% 43.9% 50.5% 51.5%

Not very helpful 5.6% 2.2% 3.9% 7.2% 8.3% 9.3% 3.2% 3.0%

Not at all helpful 2.2% 0.0% 1.3% 2.1% 6.3% 2.8% 1.1% 3.0%

Don't use Campaign Guide as a resource 1.9% 4.3% 1.3% 2.1% 0.0% 2.8% 0.0% 3.0%

Don't know 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 268 46 77 97 48 107 95 66



Q22. How helpful is the Campaign Guide as a resource for completing your disclosure reports?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 41.9% 32.0% 49.5% 41.6% 39.7% 29.4% 46.6% 61.0%

No 57.8% 66.0% 50.5% 58.4% 60.3% 70.6% 52.6% 39.0%

Don't know 0.3% 2.0% 0.0% 0.0% 0.0% 0.0% 0.9% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q23. Have you ever accessed the FEC's world wide web site?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Less than 1 time 18.9% 6.3% 17.8% 22.6% 20.0% 29.8% 18.5% 8.5%

1 time 48.6% 56.3% 46.7% 53.2% 36.0% 53.2% 51.9% 40.4%

2 - 3 times 17.6% 18.8% 24.4% 8.1% 28.0% 6.4% 20.4% 25.5%

More than 3 times 12.8% 18.8% 8.9% 12.9% 16.0% 6.4% 9.3% 23.4%

Don't know 2.0% 0.0% 2.2% 3.2% 0.0% 4.3% 0.0% 2.1%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%


Sample Size* 148 16† 45 62 25 47 54 47



Q24. On average, how many times per month do you access the FEC web site?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

FEC publications such as The Record 16.9% 18.8% 15.6% 16.1% 20.0% 17.0% 20.4% 12.8%

Agency press releases 16.2% 12.5% 13.3% 19.4% 16.0% 17.0% 18.5% 12.8%

Election results, voter registration information, or turnout statistics 32.4% 25.0% 37.8% 30.6% 32.0% 34.0% 35.2% 27.7%

Official FEC forms or documents 54.7% 43.8% 57.8% 53.2% 60.0% 63.8% 48.1% 53.2%

Campaign finance reports or statistics 70.9% 62.5% 75.6% 62.9% 88.0% 57.4% 81.5% 72.3%

Don't know 5.4% 6.3% 6.7% 4.8% 4.0% 8.5% 3.7% 4.3%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total ** ** ** ** ** ** ** **

Sample Size* 148 16† 45 62 25 47 54 47


**Totals may not add to 100% because respondents could select multiple answers.


Q25. Which of the following FEC website features have you accessed?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee


Committee




All Senate House

Very accessible 50.7% 56.3% 51.1% 53.2% 40.0% 57.4% 48.1% 46.8%

Somewhat accessible 40.5% 37.5% 40.0% 35.5% 56.0% 31.9% 42.6% 46.8%

Not very accessible 4.7% 6.3% 2.2% 6.5% 4.0% 2.1% 7.4% 4.3%

Not at all accessible 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Don't know 4.1% 0.0% 6.7% 4.8% 0.0% 8.5% 1.9% 2.1%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 148 16† 45 62 25 47 54 47



Q26. How accessible is information on the FEC website?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 13.9% 14.0% 12.1% 14.8% 14.3% 11.3% 15.5% 16.9%

No 80.2% 82.0% 78.0% 81.2% 79.4% 83.1% 78.4% 76.6%

Don't know 5.9% 4.0% 9.9% 4.0% 6.3% 5.6% 6.0% 6.5%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q27. Have you ever had any interaction with the FEC enforcement staff?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 57.1% 28.6% 72.7% 54.5% 66.7% 50.0% 66.7% 53.8%

Agree somewhat 16.3% 28.6% 9.1% 18.2% 11.1% 16.7% 11.1% 23.1%



Don't know 12.2% 28.6% 0.0% 13.6% 11.1% 22.2% 11.1% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 49 7† 11† 22† 9† 18† 18† 13†



Q28. Do you agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: The FEC enforcement staff operate in an independent, nonpartisan manner.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very clear 55.1% 71.4% 45.5% 63.6% 33.3% 61.1% 50.0% 53.8%

Somewhat clear 24.5% 14.3% 36.4% 18.2% 33.3% 11.1% 38.9% 23.1%


Very unclear 2.0% 14.3% 0.0% 0.0% 0.0% 5.6% 0.0% 0.0%

Don't know 2.0% 0.0% 0.0% 0.0% 11.1% 0.0% 0.0% 7.7%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 49 7† 11† 22† 9† 18† 18† 13†



Q29. How clear were the written communications you received from the FEC enforcement staff?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 79.6% 71.4% 63.6% 95.5% 66.7% 77.8% 77.8% 84.6%

No 18.4% 28.6% 36.4% 4.5% 22.2% 22.2% 22.2% 7.7%

Don't know 2.0% 0.0% 0.0% 0.0% 11.1% 0.0% 0.0% 7.7%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size* 49 7† 11† 22† 9† 18† 18† 13†



Q30. Has the issue raised by the FEC or another party been resolved?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 55.2% 60.0% 65.9% 47.7% 54.0% 47.5% 58.6% 66.2%

Somewhat important 23.5% 22.0% 19.8% 24.8% 27.0% 22.5% 25.9% 22.1%

Not very important 4.0% 4.0% 3.3% 4.7% 3.2% 3.8% 2.6% 6.5%

Not at all important 1.1% 0.0% 3.3% 0.7% 0.0% 0.6% 1.7% 1.3%

Have not used the service 15.6% 14.0% 6.6% 21.5% 15.9% 25.0% 10.3% 3.9%

Don't know 0.6% 0.0% 1.1% 0.7% 0.0% 0.6% 0.9% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q31. How important is the following service in helping you comply with federal election law: The staff person who reviews your reports?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 33.4% 38.0% 39.6% 32.9% 22.2% 25.0% 41.4% 39.0%





Don't know 2.3% 2.0% 3.3% 2.7% 0.0% 0.6% 4.3% 2.6%

Refused 0.3% 0.0% 0.0% 0.7% 0.0% 0.0% 0.0% 1.3%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q32. How important is the following service in helping you comply with federal election law: The public affairs specialist who answers questions regarding the law?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 15.9% 24.0% 23.1% 8.1% 17.5% 13.1% 19.8% 15.6%





Don't know 0.6% 4.0% 0.0% 0.0% 0.0% 0.0% 0.9% 1.3%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q33. How important is the following service in helping you comply with federal election law: The automated Faxline for obtaining FEC information?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 17.8% 18.0% 16.5% 18.8% 17.5% 15.6% 22.4% 15.6%





Don't know 0.3% 0.0% 1.1% 0.0% 0.0% 0.6% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q34. How important is the following service in helping you comply with federal election law: The FEC newsletter, The Record?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 45.0% 50.0% 53.8% 38.9% 42.9% 35.6% 52.6% 53.2%





Don't know 0.3% 0.0% 1.1% 0.0% 0.0% 0.6% 0.0% 0.0%

Refused 0.3% 0.0% 0.0% 0.7% 0.0% 0.0% 0.0% 1.3%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q35. How important is the following service in helping you comply with federal election law: FEC Campaign Guides?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 17.8% 18.0% 18.7% 16.1% 20.6% 11.3% 18.1% 31.2%





Don't know 1.7% 0.0% 4.4% 0.7% 1.6% 1.3% 0.9% 3.9%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q36. How important is the following service in helping you comply with federal election law: The Public Records Office?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 16.4% 16.0% 17.6% 14.8% 19.0% 8.8% 23.3% 22.1%





Don't know 0.3% 0.0% 0.0% 0.7% 0.0% 0.6% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q37. How important is the following service in helping you comply with federal election law: FEC conferences and workshops?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very important 18.1% 10.0% 15.4% 18.8% 27.0% 15.6% 16.4% 26.0%





Don't know 0.8% 0.0% 1.1% 0.7% 1.6% 1.3% 0.9% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q38. How important is the following service in helping you comply with federal election law: The FEC world wide web site?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 55.0% 60.0% 46.2% 60.4% 50.8% 50.6% 59.5% 57.1%

Agree somewhat 30.6% 34.0% 33.0% 27.5% 31.7% 34.4% 29.3% 24.7%



Neutral 0.3% 0.0% 0.0% 0.7% 0.0% 0.0% 0.0% 1.3%

Don't know 2.0% 0.0% 0.0% 4.0% 1.6% 4.4% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q39. Please tell me whether you agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: The FEC conducts business during hours that are convenient to me.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 61.5% 60.0% 65.9% 59.7% 60.3% 56.9% 71.6% 55.8%

Agree somewhat 29.5% 28.0% 23.1% 32.9% 31.7% 33.8% 20.7% 33.8%



Neutral 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Don't know 2.8% 0.0% 2.2% 4.0% 3.2% 5.0% 1.7% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q40. Agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: Overall, FEC staff demonstrate a sincere interest in solving my election law problems.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 71.7% 66.0% 75.8% 71.8% 69.8% 69.4% 73.3% 74.0%

Agree somewhat 22.7% 28.0% 16.5% 22.8% 27.0% 22.5% 23.3% 22.1%



Neutral 0.3% 0.0% 1.1% 0.0% 0.0% 0.6% 0.0% 0.0%

Don't know 3.4% 4.0% 1.1% 4.7% 3.2% 5.0% 2.6% 1.3%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q41. Please tell me whether you agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: Overall, FEC staff are courteous.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 56.4% 62.0% 54.9% 57.7% 50.8% 54.4% 59.5% 55.8%

Agree somewhat 25.8% 20.0% 24.2% 27.5% 28.6% 25.0% 25.9% 27.3%



Neutral 0.8% 0.0% 1.1% 1.3% 0.0% 0.6% 0.9% 1.3%

Don't know 10.5% 10.0% 9.9% 10.7% 11.1% 14.4% 7.8% 6.5%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q42. Please tell me whether you agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: Overall, FEC staff operate in an independent, nonpartisan manner.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Agree strongly 38.2% 38.0% 38.5% 43.0% 27.0% 36.9% 41.4% 36.4%

Agree somewhat 31.2% 32.0% 25.3% 31.5% 38.1% 30.6% 31.0% 32.5%



Neutral 1.1% 4.0% 2.2% 0.0% 0.0% 1.9% 0.9% 0.0%

Don't know 17.0% 10.0% 18.7% 19.5% 14.3% 22.5% 14.7% 9.1%

Refused 0.3% 0.0% 0.0% 0.7% 0.0% 0.0% 0.0% 1.3%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q43. Please tell me whether you agree strongly, agree somewhat, disagree somewhat, disagree strongly with the following statement: The FEC as an institution fairly applies compliance laws.

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Treasurer / Assistant Treasurer 49.6% 58.0% 56.0% 48.3% 36.5% 60.0% 46.6% 32.5%

Executive Director 6.5% 2.0% 2.2% 4.7% 20.6% 2.5% 8.6% 11.7%

Manager / Administrator 5.9% 6.0% 5.5% 8.7% 0.0% 3.1% 6.9% 10.4%

Bookkeeper / Comptroller 5.4% 6.0% 4.4% 5.4% 6.3% 3.8% 4.3% 10.4%

Administrative Assistant / Staff Assistant 2.8% 0.0% 2.2% 5.4% 0.0% 4.4% 2.6% 0.0%

Attorney / Accountant 4.2% 0.0% 1.1% 7.4% 4.8% 3.8% 5.2% 3.9%

Finance Director 4.2% 8.0% 2.2% 1.3% 11.1% 1.9% 5.2% 7.8%

Candidate 3.1% 6.0% 8.8% 0.0% 0.0% 5.6% 0.9% 1.3%

Other 17.6% 14.0% 16.5% 18.1% 20.6% 15.0% 19.0% 20.8%

Don't know 0.6% 0.0% 1.1% 0.7% 0.0% 0.0% 0.9% 1.3%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77

Q44. What is your title or role in the committee?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

1 year or less 21.8% 26.0% 35.2% 13.4% 19.0% 23.1% 18.1% 24.7%

1 - 3 years 33.1% 34.0% 30.8% 34.9% 31.7% 35.0% 30.2% 33.8%

3 - 5 years 16.4% 16.0% 8.8% 20.8% 17.5% 16.9% 18.1% 13.0%

More than 5 years 28.6% 24.0% 25.3% 30.9% 31.7% 25.0% 33.6% 28.6%

Don't know 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q45. How long have you been working with this committee with the responsibility for filing FEC reports?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Yes 5.9% 2.0% 5.5% 7.4% 6.3% 4.4% 8.6% 5.2%

No 93.8% 98.0% 94.5% 91.9% 93.7% 95.0% 91.4% 94.8%

Don't know 0.3% 0.0% 0.0% 0.7% 0.0% 0.6% 0.0% 0.0%

Refused 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q46. Have you ever tried to use the FEC's electronic filing system?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Very easy-to-use 28.6% ** ** 36.4% ** 28.6% 30.0% **

Somewhat easy-to-use 19.0% ** ** 27.3% ** 28.6% 10.0% **

Not very easy-to-use 9.5% ** ** 9.1% ** 14.3% 10.0% **

Not at all easy-to-use 33.3% ** ** 18.2% ** 28.6% 30.0% **

Don't know 9.5% ** ** 9.1% ** 0.0% 20.0% **

Refused 0.0% ** ** 0.0% ** 0.0% 0.0% **

Total 100.0% ** ** 100.0% ** 100.0% 100.0% **

Sample Size* 21† 1 5 11† 4 7† 10† 4


**Results based on sample sizes of five or less are not reported.


Q47. Would you say the FEC's electronic filing system is very easy-to-use, somewhat easy-to-use, not very easy-to-use, or not at all easy-to-use?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Candidate Committee 39.4% 98.0% 98.9% 0.0% 0.0% 35.0% 40.5% 46.8%

Political Party Committee 17.6% 0.0% 0.0% 0.0% 98.4% 12.5% 18.1% 27.3%

Political Action Committee 41.9% 0.0% 0.0% 99.3% 0.0% 50.6% 40.5% 26.0%

Don't know 0.6% 2.0% 0.0% 0.0% 1.6% 1.3% 0.0% 0.0%

Refused 0.6% 0.0% 1.1% 0.7% 0.0% 0.6% 0.9% 0.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Sample Size 353 50 91 149 63 160 116 77


Q48. Do you represent a candidate committee, a political party committee, or a Political Action Committee?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Republican 50.0% 49.0% 50.6% -- -- 34.5% 61.7% 58.3%

Democrat 44.9% 46.9% 43.8% -- -- 52.7% 38.3% 41.7%

Other 4.3% 4.1% 4.5% -- -- 10.9% 0.0% 0.0%

Don't know 0.0% 0.0% 0.0% -- -- 0.0% 0.0% 0.0%

Refused 0.7% 0.0% 1.1% -- -- 1.8% 0.0% 0.0%

Total 100.0% 100.0% 100.0% -- -- 100.0% 100.0% 100.0%

Sample Size* 138 49 89 -- -- 55 47 36

*Sample sizes based on those who responded 'Candidate Committee' to question 48.


Q49. CANDIDATE COMMITTEE: Is the candidate your committee represents a Republican, Democrat, or from some other political party?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

Republican 45.2% -- -- -- 45.2% 45.0% 33.3% 57.1%

Democrat 41.9% -- -- -- 41.9% 25.0% 66.7% 33.3%

Other 11.3% -- -- -- 11.3% 30.0% 0.0% 4.8%

Don't know 1.6% -- -- -- 1.6% 0.0% 0.0% 4.8%

Refused 0.0% -- -- -- 0.0% 0.0% 0.0% 0.0%

Total 100.0% -- -- -- 100.0% 100.0% 100.0% 100.0%

Sample Size* 62 -- -- -- 62 20† 21† 21†

*Sample sizes based on those who responded 'Political Party Committee' to question 48.


Q50. PARTY COMMITTEE: Which party does your committee represent?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





All Senate House

A PAC for a corporation 46.9% -- -- 46.9% -- 51.3% 46.8% 30.0%

A PAC for a labor union 10.2% -- -- 10.2% -- 6.3% 4.3% 40.0%

A membership or trade association 23.8% -- -- 23.8% -- 26.3% 27.7% 5.0%

An issue organization or non-connected PAC 15.0% -- -- 15.0% -- 12.5% 14.9% 25.0%

Other 2.0% -- -- 2.0% -- 1.3% 4.3% 0.0%

Don't know 2.0% -- -- 2.0% -- 2.5% 2.1% 0.0%

Refused 0.0% -- -- 0.0% -- 0.0% 0.0% 0.0%

Total 100.0% -- -- 100.0% -- 100.0% 100.0% 100.0%

Sample Size* 147 -- -- 147 -- 80 47 20†

*Sample sizes based on those who responded 'Political Action Committee' to question 48.


Q51. PAC: Which best describes the Political Action Committee you represent?

Amount of Spending


$50,000 - $500,000

More than $500,000

Type of Committee





Appendix C

FEC Program Process Maps andNarratives


PricewaterhouseCoopers LLP Appendix C1− 1

1.0 Public Disclosure Division

Process Customers

Internal: Other FEC Offices

External: Filers, Public, Clerk of the House, Secretary of theSenate

Process Descriptions

The Public Disclosure Division is divided into two offices:Processing and Public Records. Together they areresponsible for the following mapped processes: ProcessingCampaign Finance Reports (1.1), Processing AgencyDocuments (1.2), Processing Internal Agency Documents(1.3), and Responding to Information Requests (1.4). Otherdivision responsibilities include placing documents on thepublic record, developing intra-agency publications,conducting various administrative processes, answeringrequests from other agencies, and participating in the Staterelations program. These processes were not mappedbecause they represent a small portion of the total workloador because they typically are not process driven.

1.1 Processing Campaign Finance Reports was separatedinto two subprocesses, one for FEC filers and one for Senatefilers. Senate filers send their campaign finance reports to theSecretary of the Senate, while all other filers, including the

House of Representatives candidates, send their financereports directly to the FEC.

Processing Campaign Finance Reports for FEC filers beginswhen a filer sends an original campaign finance documentto the FEC. The FEC Mailroom usually receives thedocument, and the document is forwarded to the ProcessingOffice (1.1.1). The Processing Office prepares the documentfor scanning and microfilming (1.1.2). The document isscanned/filmed (1.1.3). Processing then reassembles theoriginal documents and forwards it to Data Systems for entryand coding (1.1.4).

Processing Campaign Finance Reports for Senate filersbegins when the Secretary of the Senate forwards paper ormicrofilmed Senate documents to the FEC. The ProcessingOffice receives the documents and logs in their receipt. Ifthe documents are paper, the Processing Office forwards thedocuments to Public Records, which makes the documentsavailable for public viewing. In addition, one paper copy ofthe documents is sent to Data Systems for entry and coding.If the documents are microfilm, the Processing Office splicesthe microfilm so that each office has a complete copy of thedocuments. The Processing Office then makes paper copiesof the spliced microfilm. Processing then sends one papercopy to Public Records and one paper copy to Data Systemsfor coding.



1.1.1 Receiving Campaign Finance Reports begins whenFEC filers send their disclosure reports to the FEC. Reportscan be in several forms: paper, disk Version 1, disk Version2, faxed, or via the Internet. The Processing Office processesreports that are faxed or hardcopy. Data Systems processesreports filed on diskettes or electronically through theInternet.

The Processing Office receives documents from severalsources, including the Mailroom, other FEC Offices, theClerk of the House, and Public Records. The Mailroomreceives any mailed or hand-delivered documents. Uponreceipt, the Mailroom opens envelopes, time− stamps thedocument, paperclips envelope to document, and deliversdocuments to the Processing Office. If the Mailroom isclosed (after hours), Public Records receives hand deliveriesand forwards them to the Processing Office. If another FECOffice (usually RAD) receives a campaign finance report oran amendment to a campaign finance report (sometimesreports are addressed to a RAD analyst), the office forwardsthe document to the Processing Office. If filers send Housereports to the Clerk of the House, the prior point-of-entry forHouse Reports, FEC couriers bring the reports to the FEC,and the 48-hour deadline begins when the reports arereceived at the FEC. The Processing Office receives faxedreports directly.

The Data Systems Division (Data Systems) receives allelectronic filings, which include disks. Data Systems uploads

the disks, prints the documents, and forwards paper copiesto the Processing Office, unless the electronic filing is aVersion 2 disk or filed via the Internet. (See Data SystemsDivision map, 2.1 Processing of Campaign Finance Reports(electronic) for a complete description of the process).

Processing staff log in receipt of all documents and placedocuments in Processing’s in-box for document preparation(1.1.2).

1.1.2 Preparing Documents begins when a processing clerkremoves the documents from the Processing in-box andscreens them. If the documents are Senate filings, the clerkforwards them to the Secretary of the Senate, the appropriatepoint-of-entry for Senate documents. If the documents arenot for the public record, then the Processing Office deliversdocuments to appropriate offices. If reports are FEC filingsand are for the public record, the clerk separates reports bytype of filer. The clerk separates documents by House filersand FEC Party/Non-Party filers so that the House documentscan be printed and made available to the public as soon aspossible. The clerk then prepares the documents forscanning by removing staples and separating multipledocuments. Since the envelope is difficult to pass throughthe scanner, the clerk takes the relevant information on theenvelope and completes the envelope replacement page,which is placed in back of each document. At this point, aprocessing clerk conducts a quality check by ensuring that



all documents are separated. The documents are ready toscan and film (1.1.3).

1.1.3 Scanning and Filming Documents begins when thescanner operator sets the 990 Scanner. This includes loggingonto the computer system, setting up scan/film functions,calibrating the system, and setting frame numbers. Beforeand after scanning, the operator enters data into logbook:date, operator name, filer name, and batch and imagenumbers. The operator operates the scanner and conductsrandom spot checks to ensure quality scanning. Theoperator scans batches and places the documents on a tablefor Post-Processing (1.1.4).

1.1.4 Post-Processing Documents begins after thedocuments are scanned, and the operator conducts a qualitycheck of imprint numbers to ensure that each page has beenscanned.

The clerk reassembles and staples each original, counts thenumber of documents, and records this number in a log. Theclerk prints the House reports and forwards them to PublicRecords for public viewing. The Processing Office deliversoriginals to Data Systems for entry and coding.

Post-Processing also includes processing of the microfilm.The clerk cuts the film and boxes it for messenger pickup.The messenger picks up the film and delivers it to thedeveloper. Overnight, the developer develops the film andmakes copies. The next day, the Processing Office checks

the quality of the film and splices nine copies of each roll sothat each Office can have a complete copy of thedocuments. The Processing Office delivers the film tovarious FEC Offices, including Data Systems, RAD, OGC,Press Office, and Public Records. Meanwhile, the clerkchecks the scan log. If there are errors, the clerk works withother FEC offices to resolve any entries on the Error Report. Ifthere are no errors, the clerk takes no further action.

1.2 Processing Agency Documents begins when PublicRecords receives paper documents from various FEC offices.The source of the documents can be OGC, Audit, StaffDirector, Press Office, or the Information Division.Documents include Matters Under Review (MURs), audits,advisory opinions, meeting documents, litigationdocuments, matching fund submissions, commissiondirectives, commission bulletins, publications, Sunshine ActNotices, and press releases. Once received, Public Recordsplaces the paper documents in notebooks in the PublicRecords room for public viewing. Then, every year, duringdowntime, the Processing Office indexes documents andcommits the paper to film, which is placed on the publicrecord. Agency Document Processing for the Public Recordhas one subprocess.

1.2.1 Placing a Matter Under Review (MUR) on the PublicRecord begins when OGC sends to the Processing Office theoriginal MUR. Processing prepares the MUR for filming andthen films the MUR using the microfilm camera. The



Processing Office then reassembles the original documentand returns it to OGC. Meanwhile, the Processing Officesends the film to a contractor to develop it overnight. Thenext day, the Processing Office splices the film to makecomplete copies and places the MUR in Public Records inaccordance with Directive 48. Lastly, the Processing Officedistributes film to other FEC offices and enters the location ofthe film into the MUR Search System.

1.3 Processing Internal Documents begins when an FECoffice sends the Processing Office a document to be filmed.The source of the document is usually OGC, RAD, orAdministration. The Processing Office prepares, films,reassembles, and returns the document to the appropriateDivision. The Processing Office sends the film to acontractor for overnight developing. The contractor returnsthe film to the Processing Office, where Processing splicesthe film into complete copies. Copies of the film aredelivered to the appropriate FEC office.

The Public Records Office is involved in several processes,including Responding to Information Requests (1.4). Theyare also responsible for processes that were not mapped,such as placing documents on the public record, developingintra-agency publications, conducting administrativeactivities, answering requests from other agencies, andcoordinating the State relations program.

1.4 Responding to Information Requests begins whensomeone requests information. This process will normallyfollow a phone-based information request; however,information requests can also come in via postal mail, e-mail,fax, or in person. The clerk logs in the information request onan order sheet and places the order sheet in the in− box of theChief of Public Records. During the day, the Chief of PublicRecords assigns each request to a researcher and places theorder sheet in the box of the assigned researcher. Theresearcher fills the information request and then completesand signs a cover letter explaining what information isincluded in the packet. Public Records retains the ordersheet in case follow-up is needed. The researcher placesrequested documents in an open, addressed envelope andleaves the entire packet in the in-box of the Chief of PublicRecords. The chief reviews the quality of the information, aswell as copy quality. Upon approval, the Chief seals theenvelope and places it in the out-box to be picked up by themailroom clerks. The Mailroom clerk picks up the envelope,mails it, and completes the order form with the date mailed(on mail correspondence control slip). Note: Public requestsfor information usually require in-depth research,conversation, and follow-up.

Process: Processing Reports

Process: Disclosure of Campaign Finance Information

1.0 Public Disclosure Division

For Public Record

1.1 ProcessingCampaign

Finance Reports

1.2Processing

AgencyDocuments

1.3Processing

Internal AgencyDocuments

1/15/99

Processing Office

Public Records Office

PlacingDocuments onPublic Record1

Developing IntraAgency

Publications

ConductingAdministrative

Activities

AnsweringRequests fromOther Agencies

1 Campaign Finance Records, Commission Documents, Publications, Computer Printouts2 State Relations Program includes acting as liaison with state election offices, coordinating DSD, Press Office and the state Non-Filer Program functions

CoordinatingState Relations

Program2

1.4 Respondingto Information

Requests

PDD 1

Originaldocuments1

1.1 Processing Campaign Finance Reports

Original document Original documentData

Division

Senate Filers

PaperData

Systems

PublicRecords

Paper

Aredocuments

paper ormicrofilm?

Microfilm

2 Senate filers send the Secretary of the Senate paper reports. The Secretary films the reports and forwards the paper copy to the FEC. Then, after 500 pageshave been filmed, the Secretary forwards the microfilm to the FEC.

1 12 different types of documents

Public Disclosure Division

1.1.1Receive

documents(Processing

Office)

1.1.2Prepare

Documents

1.1.3 Scan/FilmDocuments

1.1.4Post-Processing

(reassembledocuments)

Make paper copyof film and splicefilm into 9 copies

Log in receipt

1/15/99

Secretary ofthe Senate

Filer

Paper orMicrofilmReports2

FEC Filers (Including House of Representatives)

PDD 2

1copy

of film

Other FECOffices

8copiesof film

1.1.1 Receiving Campaign Finance Reports

Paperreports,disks 1

Disks4

Other FECOffices

(typicallyRAD)

Clerk of theHouse5

DataSystems6

Paper

1 48-hour clock begins from date of receipt in FEC building (by statute). Although the Mailroom receives both Version 1 and 2 of disks, Data Systems only makes a copy of Version 1 to forward to theProcessing Office. This process only tracks what is processed by the Processing Office. Internet, modem and version 2-based filings are processed by either Data Systems or the electronic filingcontractor, SDR. See Data Systems’ 2.1 Processing of Campaign Finance Reports (electronic) process for a complete process description.2 Receive hand deliveries if Mailroom is closed3 Mailroom opens envelopes, time stamps, paper clips envelope to documents, and delivers documents to Public Disclosure Division; Receives hand deliveries as well. For disks, notifies SDR(contractor) by phone and SDR comes to get disks4 A paper copy is only made of Version 1 of software and forwarded to the Processing Office.5 Two deliveries a day6 Receives and processes electronic filings7 Incoming log data can be used to track source of documents, elapsed time, touch time


Mailroom3

Log-in receipt ofdocuments7

Place inProcessing inbox

1/15/99

ProcessingOffice

Faxes ofDisclosure Reports

Filers

Hand deliveries IfMailroom closed

1.1.2Preparing

Documents

PDD 3

PublicRecords2

Aredocumentsaddressed

toProcessing

Office?

no

yes

Version 1paper copy

1.1.2 Preparing Documents

Screendocuments

Prepare forscanning3

Separatereports byform type2

Completeenvelope re-placement

page4

Aredocumentsfor PublicRecord ?

yes

Deliverdocuments

toappropriate

offices

no

Deliver toSecretary of

Senate1

Performquality

control pre-scanning

Aredocuments

Senatefilings?

no

yes

1.1.3 Scanning and Filming Documents

Set 990Scanner1

Operatescanner and

conductrandom spot

checks

1 FEC is not the first point-of-entry for Senate documents2 Separate documents into House filers and FEC party/non-party filers to track image frame numbers so paper copies can be made of House documents and be available to public moreimmediately among other reasons3 Remove staples and separate multiple documents4 Discard envelope

Inboxdocuments


1 Log onto computer program, set up scan/film functions, calibrate system, set frame numbers 2 Log by batch: date, operator name, filer name, and batch numbers

Scandocuments

1/15/99

1.1.1Receiving

Documents

1.1.3Scanning

and FilmingDocuments

1.1.4 Post-processing

1.1.2Prepare

Documents

Logbeginning

frame to bescanned2

Log finalframe

scanned2

PDD 4

1.1.4 Post-Processing Documents

Batches oforiginals1

1Quality Control: Data Clerk goes through each PDD to ensure each PDD has been filmed/scanned by checking each PDD for 990 imprint numbers2 Staple documents by Envelope Replacement PDD

PublicRecords

Data Systems

3 Overnight delivery of film copies4 Quality control check of film to ensure good quality, verify content, and take density reading5 Error Report with beginning and ending frame numbers6 Data Systems, RAD, OGC, Press Office, and Public Record7 Usually RAD or Data Systems

DataSystems,

RAD, OGC,Press Office,and PublicRecords

Next Day

Messengerpicks up,

develops andcopies3

Does the imagescanned by

Processing matchthe data entered by

Data Systems?

no

yes

Public Disclosure Office

Film

1/15/99

Reassembledocuments2

Count number ofdocuments and

record in log

Deliver reports toData Systems

Print papercopies of House

Reports

Cut and box filmSplice ninecopies from

received rolls

Check scan logand trouble

shoot5

Deliver copies offilm to variousFEC offices6

Work with otheroffices to solve

problem7

No action needed

1.1.3 Scanand Film

1.1.3Scanning

and Filming

paper documents

PDD 5

Receive film4

1Documents include closed Matters Under Review (MURs) (placed on Public Record as received because of Directive 48 and 11 CFR 111.20 specify a deadline of 30 days after being closed), Audits,Advisory Opinions, Meeting Documents, Litigation, Matching Fund Submissions (Placed on Public Record as received - once every four years), Commission Directives, Commission Bulletins,Publications, Sunshine Act Notices, Press Releases

1.2 Processing Agency Documents

1/15/99

Office ofGeneralCounsel

Audit

StaffDirector

Press Office

InformationDivision

PublicRecords

PaperDocuments1

Place paperdocuments innotebooks in

Public RecordsRoom

Every 2 years, indowntime,

commit paper tofilm

Public Disclosure Division PDD 6

OriginalMUR

1.2.1 Placing a MUR on the Public Record

Original document Original document OGC

Film

Contractor(overnight

processing)

ProcessingOffice

Receivedocuments(Processing

Office)

Preparedocuments

Film documentsPost-processing

(reassembledocuments)

Splice filmPlace in PublicRecords andother Offices

OGC

Originaldocument1

1.3 Processing Internal Documents

Original documentOGC, RAD,

Admin-istration

Film

Contractor(overnight

processing)

ProcessingOffice

1/15/99


Post-processing(reassembledocuments)

Film documentsusing microfilm

camera

Preparedocuments

Receivedocuments(Processing

Office)

Splice film

Deliver copies offilm to

appropriateoffices

Originaldocument

FEC Office

1 Payroll, internal RAD files, etc...

PDD 7

1.4 Responding to Information Requests

Receivedocument/informationrequest via

phone1

1 Requests also come in via mail, e-mail, fax, and in person2 Only applies to mail correspondence control slips

Log in request onorder sheet

Place order sheetin box of Chief ofPublic Records

During the day,Chief assigns

requests

Chief placesorder sheets inbox of assigned

researcher

Researcher fillsrequest

Complete & signcover letter in

case follow-up isneeded

Researcher putsrequested

documents inopen addressed

envelope

Researcher putsopen addressedenvelope in thebox of the Chief

Chief reviewsinformation and

print quality

Mailroom picksup sealed

envelope andmails

Mailroomcompletes orderform with mail

date2



2.0 Data Systems Division

Process Customers

Internal: RAD, Public Disclosure, OGC, Audit

External: Filers, Public


The Data Systems Division (Data Systems) is responsible forpreparing and collecting data, disseminating data, andassisting with information technology. Preparing andcollecting data includes making public within 48 hoursrequired campaign finance information, which is captured inthe Processing Campaign Finance Reports Process (2.1).Information technology assistance is not mapped because ofthe varying nature of the requests and responses.

2.1 Processing of Campaign Finance Reports (manual)begins when the filer sends campaign finance documents tothe FEC. The Mailroom receives disks (Versions 1 and 2) aswell as paper documents, while Data Systems receiveselectronically filed forms. The Mailroom forwards disks toData Systems. Data Systems uploads the data on both typesof disks. Version 2 disks filter into the electronic processingof campaign finance documents, and Version 1 diskinformation is processed manually. Data Systems prints theinformation on the Version 1 disk and forwards the paper

copy to Processing for imaging. Processing also receives allpaper copies of filings directly from the Mailroom, which arealso imaged. When Data Systems receives the originaldocuments from Processing, they log and sort the documents(2.1.1). Next, coders code the documents (2.1.2). Then thedata entry staff enter the coded information into the system(2.1.3). Overnight, the system compares the image to whatwas entered and marries the data. The next day, a differentdata entry staff member enters the same data as a qualitycheck (2.1.4).

If the document has itemized transactions, it needs furthercoding and entry (Pass III) (2.1.5). If the document does notneed further coding, then the original document isforwarded to the RAD file room for analysis. Once Pass IIIcoding is complete, Data Systems decides whether to do thedata entry in-house or contract it out to ILM inFredericksburg, Virginia. Either way, once Pass III data entryis complete (2.1.6), the system updates the data in thedisclosure database.

Processing of Campaign Finance Reports (electronic) beginswhen either the Mailroom forwards Version 2 disks to DataSystems or the Filer electronically submits forms via theInternet. Once disks are received, Data Systems uploads thedata. Then the system verifies the data, populates thedatabase, creates TIF files, creates two sets of data files (PassI and Pass III), and updates the disclosure database.



Before the disclosure database is updated, Data Systemsconducts exception processing, a quality-control check.Also, when Data Systems receives electronically filed forms,they print out the forms and forward them to RAD.Processing Campaign Finance Documents manuallyincorporates six subprocesses.

2.1.1 Logging and Sorting for non-Senate documents beginswhen Processing sends Data Systems the paper non-Senatefilings. Data Systems updates the log with the date, time,beginning and ending image frames, year, office, andlogger’s initials. If there is a problem, Data Systems checkstheir log against Processing’s log. Data Systems verifies thatthe documents are sorted by House and Non-Party filers. Asenior coding specialist distributes documents to assignedindividuals for Pass I coding.

Logging and Sorting for Senate documents begins whenProcessing sends Data Systems the paper Senate filings. DataSystems updates the Senate log and assembles thedocuments for Pass I coding.

2.1.2 Conducting Pass I Coding begins when coders identifyreport type and check for line consistency. Then theyidentify committee type, coverage dates, amendmentindicator, primary/general indicator (3, 3p), and databasereceipt date. Next, they color− code documents by

committee type with stickers.1 Coders then check theidentification number in the appropriate database and assignidentification numbers for new 1, 2, 5i, 7, and i (if required).If the report covers more than one report type, the codermust generate a cross-referencing page (substitute sheet) tobe scanned, coded, and entered as an additional report.Coders then sort documents by database.2 Lastly, the coderscount documents and time spent coding for timesheet. Thedocuments are now ready for Pass I data entry.

2.1.3 Conducting Pass I Data Entry begins when a DataSystems staff member manually logs in the documents bybatches. The data entry clerks pick up batches of paperdocuments and sort batches by form type. Each type ofdocument has a unique screen for data entry. Separatingdocuments eliminates toggling between screens. The dataentry clerks enter the data that has been coded. Whenfinished, they place the original document in a specified filecabinet for the evening. Overnight, the system automaticallyupdates the disclosure database(s) and ties the imageddocument to the information that has been updated. Inaddition, the system begins the automatic tracking system,enters and verifies the data, updates processes, and identifieserrors. The system conducts logical checks for duplicates,

1 Committee types are Presidential, House, Senate, Party, and Non-

Party.2 There are separate databases for each two-year election cycle.



etc. The next day, a different technician takes a batch ofdocuments and prints out a copy of an RP1.3 Once theupdate process begins,4 the system cannot be used until thefollowing morning.

2.1.4 Conducting Pass I Data Entry/Verification (doubleentry) begins when the second technician rekeys the codeddata and corrects any data entry errors using the RP1 reportinformation. The technician flags documents with errorcodes for special handling by a senior coder. The systemthen applies RAD’s priority threshold indicators to thedocument, and if the document meets or exceeds thethreshold level, the system prints “Priority” on theverification printout for those documents. Prioritydocuments are those that RAD needs to work on as soon aspossible, and the priority label tells Data Systems to codeand enter these documents before nonpriority documents.The technician then sorts the documents, based on priorityand filer type. Next the technician brings the batches toassigned areas, based on filer type.

2.1.5 Conducting Pass III Coding begins when coders sortthe documents to determine whether Pass III coding isneeded. Itemized and codable transactions of new/amendeddocuments must go through Pass III coding. If Pass III coding

3 The RP1 printout consists of the Pass I Data Entry Journal with error

codes.4 Around 7:30 p.m.

is not necessary, coders manually update the Reports StatusSystem (RSS) with the date that the file was sent to RAD andforward the documents to the RAD file room. If Pass III isneeded, coders analyze and code the documents and countthe transactions. Data Systems then determines if thecontractor should enter the data for Pass III or if data entryshould be performed in-house.5 If the contractor performsPass III entry, Data Systems limits batches to 4,000transactions6 and sends them to the contractor for entry. Atthe end of each day, coders update RSS with the number oftransactions and batch documents coded that day.

2.1.6 Conducting Pass III Data Entry/Verification beginswhen Data Systems either sends documents to the contractorfor entry or performs data entry themselves. If the contractoris responsible for performing Pass III entry, the contractorenters the data and returns the documents to Data Systems.A senior coder checks all contractor-entered documents foromissions/errors, corrects errors, and performs additionaldata entry, if necessary. Once data entry is complete, thedocuments are sent to the RAD file room.

5 Most documents for prior election cycles and low− volume

amendments for the current election cycle stay in-house.6 FEC pays the contractor on a per transaction basis.



If Data Systems conducts Pass III data entry, then data entryclerks enter the data and forward the original files to theRAD file room. The data, which is now in the system, isautomatically updated overnight. The system prints out ajournal if any reconciliation errors are found. The disclosuredatabases are populated. No matter who performs dataentry, Data Systems updates the RSS system with the datethat entry was completed.

DataPreparation/Collection

Data Dis-semination1


InformationTechnologyAssistance2

(Manufacture of disclosure database)

2 Information Technology includes: network administration, programming, operations, technical support and training, research and development (strategic technical planning)

1Data Dissemination includes programming and indexing journals.

DSD 1

1/15/99


2.1.1Logging and

Sorting

Paperdocuments1

ProcessingOffice images

documents

Uploaddata

Populatedatabase

Exceptionprocessing

(qualitycheck)

Upload &printdata 3

Mail Room Disks(Versions 1&2)

paper

Data Systems

Data Systems

ElectronicallyFiled Forms2

ExternalFiler

Verify data

Data Systems

Automatic by the System

Manual Processing

Electronic Processing

CreateTIF files

Create twosets of datafiles (Pass 1

and 3)

Version 2 Disks &Direct E-Filing

B

A

Print reportsand forward

to RAD

2.1 Processing of Campaign Finance Reports

DSD 2

1/15/99

Version 1

RAD

1 House, Senate, FEC Party/Non-Party, Presidential2 Modem (version 2), Internet (version 2)3 Upload file and print document for RAD at RAD’s request. Estimated time: 4 hours

2.1.3Conduct

Pass 1 DataEntry

2.1.2ConductPass 1Coding


Contractorconducts

Pass 3 dataentry

RAD FileRoom

Does theform need

furtherprocessing?

4

no

yes

Contractorperforms

data entry?5yes

2.1.6 FECConducts

Pass 3 DataEntry

no

Updatesystemdata6

DisclosureDatabase

2.1.4Conduct

Verification ofPass 1 Data

Entry (DoubleEntry)

Pass 1

Overnight

Summary Data

Data Systems Division

A

B

2.1 Processing of Campaign Finance Reports, continued

Electronic Processing

Pass 3

Manual Processing

DSD 3

1/15/99

4 Forms 1, 2, 6, MS, 1M go to RAD File Room; Forms 3, 3P, 3x, 5i, 7, i and 4 get coded.5 Volume, specific situation, etc. warrant use of contractor. Currently, the contractor is ILM.6 System automatically updates database overnight.

2.1.1 Logging and Sorting

2.1.2 Conducting Pass 1 Coding

Paperdocuments

DataProcessing

Paperdocuments

DataProcessing

Paperdocuments2

Senate Documents

Non- SenateDocuments

Update log1 Check log againstProcessing’s log

Verify documentsare sorted: House

v. Party/Non-Party Filers

Count anddistribute to

assignedindividuals

Update Senatelog3

Assembledocuments

Analyze & codedocuments

Identify and colorcode by

committee type1Sort by database3

1/15/99


Checkidentification

number inappropriatedatabase2

Initial and datereport

Count and timefor timesheet

Assign IDs fornew 1,2, 5, 7, 5i, i

if required

DSD 4Data Systems Division

1 Date, time, beginning and ending image number, year and office (03 - FEC, 02- Senate), logger’s initials. This log is used by Irene to compare with Processing’s log.2 Photocopies of originals3 Log is used to ensure duplicate copies do not exist because Senate sends over microfilm once a week and paper once a day.

1 Identify Presidential, House, Senate, Party, Non-Party with color-coded stickees. Check B-Index if don’t know committee type.2 So no duplication of documents.3 FEC maintains separate Databases by 2-year election cycle


2.1.1 Log& Sort

2.1.3ConductPass 1DataEntry/

Verification

2.1.3 Conducting Pass 1 Data Entry

Batches ofpaper

documents

1 Each type of document has a unique screen for data entry. Separating documents eliminates toggling between screens2 First step in creating an electronic document - ties images together3 The System begins to update around 7:30 p.m. - takes approximately 12 hours. During the update process, no work can be done with the system until 7:30 a.m. The update begins Auto TrackingSystem which is the first initial check of reporting error - conducts logical checks for duplicates, etc.4 Keep in order as entered. Store in special area.5 RP1 Printout consists of Pass 1 Data Entry Journal with error codes

Automated update overnight3

2.1.4 Conducting Pass 1 Data Entry Verification (Double Entry)

1/15/99

Log in receipt ofdocuments

Data entry clerksget batches

Sort batches byform type1

Enter data intoscreens2

Store in filecabinet

Differenttechnician takesbatch & takes

RP15

Rekey data andmake anynecessarycorrections

over-night

Systemdetermines case

priority1

Technician sortsdocuments basedon priority & filer

type

Technician bringsbatches to

assigned areasbased on filer

type

1 Priority labeling requested by RAD. RAD determined the threshold level and the system is set to print "Priority" on the verification printout.

Original paper copy4

Flag documentswith error codes

for specialhandling

DSD 5Data Systems Division

2.1.4Conduct

DataEntry/

Verification


2.1.3ConductPass 1

Data Entry


Batches

1 Itemized and codeable transactions of new/amended documents must go through Pass 3 Coding2 Amendments almost always stay in-house. Primarily, current election cycle database documents go to the contractor. Documents for different election cycles cannot be combined in the same batch.

Is Pass 3needed?1 yes

RAD fileroom

no, manually update RSS

Volume ortype of

documentwarrant

contractor?2

Sort documentsto determine if

Pass 3 coding isneeded

Analyze and codedocuments

Coder countstransactions

Limit batch to4000 transactions

yes

Update RSS withnumber of

transactions &batch documents

End of day

Conduct Pass 3data entry in-

house

Send documentsto contractor

DisclosureDatabase(s)populated

data

DataSystems

Contractorperformsdata entry

2.1.6 Conducting Pass 3 Data Entry/Verification

RAD FileRoom

Folder

Documents

Systemautomatically

updates databaseovernight

System prints outjournal if any

errors inreconciliation

Differenttechnician takesbatch and prints

out SP104

Rekey data andmake anynecessarycorrections

Update RSSminus number of

in-housetransactionsno

Checkdocuments for

errors/ommissions and

correct

DSD 6

2.1.5 Conducting Pass 3 Coding


1/15/99

2.1.6ConductPass 3

Data Entry

A

A

2.1.4Conduct

DataEntry

Verification



PricewaterhouseCoopers LLP Appendix C3 − 1

3.0 Reports Analysis Division

Process Customers

Internal: OGC, Audit, Data Systems, Public Records, andInformation Division

External: Filers, Public, and Candidates


The Reports Analysis Division responsibilities are dividedinto five mapped processes and one not-mapped process,Processing FOIA Requests.

3.1 Processing Campaign Finance Documents begins whenData Systems completes the required data entry (Pass I orPass III) of campaign finance information. Data Systems thenforwards the original campaign finance documents to theRAD file room, which houses current election cyclecampaign finance documents. Upon receipt, a file roomclerk sorts the documents by committee type and files thedocuments in file folders chronologically and by form type.Reports analysts have access to a workflow program that,when queried, allows them to view the committees to whichthey have been assigned. The analyst chooses a committeeto review and pulls that committee’s file folder. Rather thanuse the original paper document to review the data, the

analyst can work off the report image. Either way, the reportsanalyst begins to review and analyze the report.

3.1.1 Reviewing and Analyzing the Report begins when thereports analyst compares the original document with the RIndex. The R Index provides a history of the committee’sfilings, based on Pass I data entry. For example, the R Indexshows whether a previous filing was new or amended, thetype of document (monthly, midyear, etc.), the beginningcash on hand, coverage dates, total receipts, and endingcash on hand. The analyst then reviews for compliance,which consists of mathematical, content, and disclosureanalyses. The analyst notes any compliance problems on hisor her logbook. Missing or perceived incorrect informationtriggers the Request for Additional Information Process (3.2).

At any time in the process, if the analyst finds data entryerrors, the analyst sends the file containing the originaldocument back to Data Systems for correction. Data Systemscorrects the error(s) and sends the folder to the RAD fileroom. If the analyst uncovers any compliance problems, heor she sends a letter to the committee, indicating theproblems. When the compliance review is complete, theanalyst notes any problems with the report in his logbook.

If the analyst does not find any compliance problems or atthe end of the RFAI process, the analyst updates the ReportStatus System (RSS) and returns the report to the RAD fileroom. The RSS contains information about the committee’s



filings, including Pass I and Pass III start and end dates, thecoder’s name, and the date that Data Systems sent the file toRAD. Finally, the file room clerk files the report. Any reportthat is not for the current year’s database is sent to Archivesbecause of file room space constraints.

3.2 Processing Requests for Additional Information (RFAI)begins when the analyst conducting the document reviewneeds additional information from the filer to complete thereview. The reports analyst decides whether the letter istracked (RFAI) or nontracked (informational). If the letter isnontracked, the reports analyst sends an informationalnotice to the filer. The reports analyst fills out with codesone transmittal form per request and forwards all formsrelated to a committee to the secretary for completion. Fromthe codes, the secretary composes a letter and returns theletter to the reports analyst for review. The reports analystreviews the letter and, if complete, signs the letter andforwards it, along with the appropriate folder, to the branchchief for approval. The reports analyst retains a copy of theletter, puts a copy of the RFAI into the committee’s folder,and returns this folder to the RAD file room. Meanwhile, thebranch chief reviews the letter and, if there are no problems,forwards the letter to the Compliance Branch. If there is aproblem, the branch chief sends the letter back to theanalyst, who corrects the problem and sends the edits to thesecretary for retyping. Once typed, secretary gives the letterback to the analyst, who forwards it to the branch chief for

another review. Once the letter is correct, the branch chiefforwards the letter to the Compliance Branch.

The Compliance Branch tracks the mail date and makes twocopies of the letter. A compliance analyst enters the RFAIdata into the disclosure database. A compliance analystsends the original letter to the filer, forwards one copy toPublic Records, and retains one for the compliance files.

The filer is given 15 days in the letter to respond to the RFAI.If the filer does not respond in three weeks (21 days), acompliance analyst sends the filer a second RFAI letter.Once again, the filer has 15 days to respond to the RFAI. Ifthe filer still does not respond, the reports analyst identifiesany outstanding issues. These issues are weighed in terms ofimportance and whether the filer should be referred to Auditor OGC. If RAD decides not to refer the matter to Audit orOGC, the outstanding issues remain outstanding and arenoted on the analyst’s log for possible action at a later date.

If the filer responds in 15 days, the compliance clerk reviewsthe response to see whether the response is adequate. If theresponse is adequate, the reports analyst reviews theresponse for accuracy and for compliance problems. If theanalyst finds that the response is not accurate or that othercompliance problems exist, the analyst notes the problemsas an outstanding issue. If the analyst discovers acompliance problem, he or she must determine whether it isan audit issue (assign audit points) and/or a legal issue. If the



filer receives enough audit points, RAD refers the committeeto the Commissioners for a possible audit. If the analystfinds a problem that meets OGC’s threshold, the analystprepares review documents for OGC and forwards a referralto them. Otherwise, the issues remain outstanding.

3.3 Processing Non-Filer Notices begins when a complianceanalyst reviews a computer printout of filers who have notfiled by the deadline. The compliance analyst provides thereports analyst with the names of the non- or late filers. Thecompliance analyst checks with other departments to seewhether the report has been filed, and whether Processing,SDR (the electronic filing contractor), and/or Data Systemsare still working with the report. If the report has not beenfiled, the compliance analyst sends the filer a nonfilernotice.

3.4 Processing Debt Settlements. According to law,committees must settle debts with creditors, so to helpfacilitate settlement, FEC requires the committees to file aDebt Settlement Plan. Debt Settlement Processing (DSP)begins when the reports analyst receives the debt settlementrequest from a committee attempting to terminate. Thereports analyst forwards the request to the complianceanalyst and PFESP staff. The compliance analyst reviews theDSP and sends the committee an RFAI if needed (begin 3.2RFAI Process). Once all information is received from therequester, the compliance analyst determines whether thecommittee meets the criteria for a debt settlement. If the

committee meets the criteria, the FEC accepts the settlementwith a possible PFESP review and closes the case. RAD tellsPFESP that the matter meets the review threshold. PFESPprepares a formal memo to the Commission, analyzing therequest and making recommendations to the Commission.The Commission reviews the recommendation, and if theCommissioners approve the termination and/or settlementapproval letter, the compliance analyst sends the committeea settlement approval letter and a termination letter, ifappropriate.

If the committee does not meet the criteria, the settlement isnot accepted, and the compliance analyst sends thecommittee a letter saying that the settlement offer was notapproved.

3.5 Processing Administrative Terminations. Committeesare required to file campaign finance reports even if nomoney has exchanged hands. Since it costs money to havenonfilers in the system, RAD has a process that “terminates”committees so that they are not required to file. ProcessingAdministrative Terminations begins when either RADperiodically reviews its files or when a committee requestsan administrative termination. RAD, with OGC/PFESPassistance if necessary, determines whether the filer meetsthe thresholds for administrative termination. Either way,RAD sends the filer a letter indicating its decision. If RADreceives no response, then the filer is automaticallyadministratively terminated.

3.0 Reports Analysis Division

3.1 ProcessingCampaignFinance

Documents

3.2 ProcessingRFAIs

3.3 ProcessingNon-Filer Notices

3.4 ProcessingDebt Settlements

3.5 ProcessingAdministrativeTerminations

Processing FOIARequests

1/15/99

RAD 1

RAD FileRoom

Work offimage?


3.1 Processing Campaign Finance Documents

yes

no, paper copy

3.1.1 Reviewing and Analyzing Reports

Are theredata entry

problems?2no

3.1.2 Updating Status Report and Refiling Original Documents

Are therecomplianceproblems?

no 3.1.2

ReportsAnalyst

1/15/99

Data Systems

OriginalFile

(Senatecopies)

1 Report Analysts can use a Workflow Program (Program 117) any time to see which committeesthey are assigned which have documents to be reviewed

yes

File room clerksorts documents

by committeetype

File room clerkfiles documentsby form type andchronologically in

file folders

Reports analyst1

pulls file folder ofassigned

committee

Review reportCompare originaldocument against

R index

Conductmateriality review

formathematical,content, and

disclosure issues

Copy data entryproblem

information

Send correctionsto Data Systems

Data SystemsCorrects Data

2Data entry problems can be identified throughout the review of the report. The analyst compares the coder’s marks with what should have been coded and what was entered intothe database. Problems are noted and when the Compliance Review is complete, the corrections will be sent to Data Systems for correction.

Archives3

3Reports are archived August of the non-election year because of file room space constraints

RAD 2

3.1.1 Review &Analyze Report

3.1.2 UpdateReport StatusSystem (RSS)

and return folderto file room

3.2Processing

RFAIs

3.2Processing

RFAIs

3.1.1Review &AnalyzeReport

3.2 RFAIProcess

Note problems onlog sheet

yes

RAD FileRoom

original

File room clerkfiles report/folder

Reports analystreturns file toRAD file room

inbox

Reports analystupdates RSS


3.2 Processing Requests for Additional Information (RFAIs)

ReportsAnalyst

Track ornon-track

RFAITrack

Copy 1

DFiler receives

RFAI

1/15/99

Non-Track

Sendinformationalnotice to filer4

Reports analystcompletes

transmittal formwith codes/ edits

returned letterand forwards to

secretary

Secretarycomposes letter/edits letter and

returns to reportsanalyst

Reports analystreviews and signsletter and send sto Branch Chief

Branch chiefreviews

document

Does theletter need

editing?

Branch chiefsends completed

letter toCompliance

no B

yes

B

ComplianceBranch tracksmail date and

makes two copiesof letter

Send originalletter to filer

Copy 2

Original

Complianceanalyst places

copy 2 withtransmittal sheetin ComplianceBranch folder

Processingmicrofilm& image

C

4 Informational Notices inform the Filer of future actions to take which would make analyzing the report easier. No reply is required.

RAD 3

3.1 ProcessingCampaignFinance

Documents

Reports analystretains a copy for

his records

Enter RFAI datausing data entry

screen

RAD FileRoom

B

D

Does filerrespondwithin 15

days?

Fileresponse in

RAD fileroom

yes

RAD

ComplianceAnalyst

retrieves &reviews

response

Is responseadequate?

Reportsanalystreviews

response foraccuracy

yes

Does theinformation

triggercomplianceproblems?

yes

Identifyoutstanding

issuesno

no

Complianceanalystsendssecond

RFAI letter


3.2 Processing Requests for Additional Information (RFAIs) (Continued)

no

Does Filerrespondwithin 15days?4

yes

no

1/15/99

C

Identifyoutstanding

issues

RAD 4

Are thereoutstanding

issues?yes

E

EAssign audit

points?

Refer toOGC?

yes

yes

Letoutstandingissues stand


3.2 Processing Requests for Additional Information (RFAIs) (Continued)

RAD 5

Do totalaudit points

meetthreshold?

yes

no

nono

1/15/99

Commissionreceives file

OGC receivesreferral doc-umentation

3.3 Processing Non-Filer Notices

Reviewcomputerprintout1

ComplianceBranch

1 Printout indicates who has not filed2 Report might have been received, but in processing. Analyst checks with Mail Room, Processing and Data Systems.3 Mail by the 4th of the month

Check tosee if report

has beenfIled2

3.4 Processing Debt Settlements

Reportsanalyst

receivesdebt

settlementrequest

3.5 Processing Administrative Terminations (AT)

Periodicallyreview riles

Send letterto filer

concerningtermination

decision

1/15/99

Reportsanalyst

forwardsrequest to

complianceanalyst

Track dateand send

RFAI to filer

Acceptsettlement

Complianceanalysts

closes case

Complianceanalyst

sends filerletter

Receiveresponsefrom filer

Send non-filer notice to

filer viaWestern

Union

Committeerequestsadmini-strative

termination

If committeedoes notrespond,they are

automatically terminated

Meet ATthreshold?

RAD 6

Does theresponsemeet debtsettlement

requirements?

Do notaccept

settlementoffer

Send letterto filer that:settlement

was notapproved

yes


PFESPanalyzes

request andprepares

formalmemo

Commissionreviews

settlementrecommend

ation

Accepts

Send toPFESP forlegal reviewand analysis

no

yes

Do notaccept

PFESPconducts

review usingRAD’s

relevantinformation

Ask PFESPto check

enforcementand litigation

files

PFESPemailsreview

results toRAD

Prepareformalmemo

analyzingrequest and

makingrecommend

ations

Commissionreviews

terminationrecommend

ation

non-routine

routine



4.0 Audit Division

Process Customers

Internal: OGC, RAD

External: Filers, Public, Department of the Treasury


The Audit Division is responsible for processes within thefollowing categories: Audit-For-Cause (4.1), Audit-For-CauseReferral (437(g)) (4.2), and Presidential Public FundingProgram (4.3).

4.1 Audits-For-Cause. For purposes of analysis, this processhas been separated into four subprocesses.

4.1.1 Preparing for Commission Vote and NotifyingCandidates/Committees begins when the staff at the ReportsAnalysis Division (RAD) reviews each report filed by Federalcandidates, committees, and political parties to ensure thatthey have complied with the disclosure requirements andthe limits and prohibitions on contributions. A confidentialpoint system is used to assign points to violations of FECA.When RAD recognizes areas of apparent noncompliance ordeficiencies, it assigns points to the reports. Once a certainthreshold of points is reached, the referral is forwarded tothe Audit Division for further investigation.

Audit receives these referrals in batches from RAD. Theygenerally receive the candidate committee referrals in Marchfollowing the year of the general election. The statutewritten by Congress requires FEC to initiate the audit withinsix months after the general election. Once the pool ofreferrals is received from RAD, Audit has six weeks to getauthorization from the Commissioners and commence theaudit.

For referrals of noncandidate committees (e.g., PACs, Partycommittees), Audit also receives these referrals in batchesfrom RAD, generally during the period from August toDecember following the year of the general election. Thestatute requires FEC to initiate the audit within 30 days of theCommission’s vote to conduct an audit.

In the case of candidate committee referrals, after Auditquickly reviews the referrals, Audit attaches a cover letterand takes them to the next Commission meeting forapproval. The Commissioners and Audit decide on howmany audits they are capable of completing, given thetiming and the available resources. They generally willselect for audit the referrals that generated the most points.Four out of six Commissioner votes are needed for approval.The referrals that fail to get Commissioner approval or arenot pursued because of lack of resources are consideredclosed at this time. However, referral to OGC from RADmay still be considered.



For noncandidate committee referrals, Audit also conducts aquick review of the referrals and then attaches a cover letterrequesting that the Commission determine which referralswill not be subject to audit. Audit forwards those remainingreferrals to the Commission for approval to conduct an auditas resources permit.

Once approval is granted, the Audit Division sends anovernight engagement letter to the committee stating that ithas been selected for an audit. This document requestscertain key information that the auditors will need to look atin advance to start the fieldwork. The auditors will thencontact the candidate or committee to schedule thefieldwork. The auditee can either have the auditors startright away or request a delay. In the latter case, the auditwill be scheduled outside the 30-day or six-month window.This contact of the candidate/committee and scheduling arepresumed to be initiation of the audit, meeting statutoryrequirements.

4.1.2 Conducting Preaudit begins when auditors contactRAD and the Office of the General Counsel (OGC) todiscuss any pending items concerning the auditee such asMatters Under Review (MURs). They review past andpresent reports to see trends and identify different areas onwhich they may want to focus more attention during theaudit. They analyze the receipts and disbursements asdisclosed in the reporting. They reconcile these data and set

up to compare them to the financial data provided by thecandidate/committee.

When a candidate/committee is selected for an audit-for-cause, a full-scope audit is always done. After the auditorscomplete their analysis in the preaudit process, amodification of the audit program may be necessary tofurther focus analysis .

4.1.3 Conducting Fieldwork begins when Audit conducts anentrance conference with the candidate/committee. Thisconference explains, in general terms, why they wereselected for an audit, what they can expect, and also whatinitial information the auditee will need to provide. Theauditee also provides the auditors contact names to use inthe field.

The auditors first conduct an inventory of records, includinglimited testing to determine whether the records arematerially complete and in an auditable state. If a materialportion of the records have not been provided, the auditee isnotified in writing and given 30 days to obtain the requestedrecords. If at the end of this 30-day period the records areavailable, fieldwork will commence. If not, the auditorsmay recommend to the Commission that subpoenas forrecords be authorized, both to the auditee and any otherentities in possession of the relevant records.



Once the records are deemed materially complete, theauditors conduct the fieldwork, using the audit programdeveloped during the preaudit phase. They perform testsand, depending on the amount of activity, use samplingmethods to test the auditee’s transactions. They gatherevidence and data to support the findings in the final reportand to maintain as workpapers.

At the end of the fieldwork, an exit conference is conducted.At this time, the auditors disclose to thecandidate/committee material findings based onpredetermined thresholds that are standard for all audits.

When the auditors leave the field, the auditee has 10 days tosubmit an official response to the findings disclosed at theexit conference. The auditee may send the auditors anydocumented evidence, receipts, or reports that may prove afinding incorrect.

4.1.4 Conducting Postaudit and Processing the AuditReport begin when the auditors return from the field. Theauditors prepare an interim audit report that discloses anymaterial findings. This report encompasses all responsessubmitted by the auditee after the exit conference. Theauditors consider the magnitude of the findings and decidewhether the findings are sufficient enough to include in thereport. The auditors compare the findings to the parametersset by the Commission and also determine whether furtheranalysis by the OGC is warranted.

At this time, the Audit staff completes the audit program andindexes the workpapers. The manager of the team reviewsthe workpapers. Once the draft interim report is completed,it, along with the workpapers, undergoes a peer review.

If the findings are significant and do not contain anyunresolved legal issues, the report is prepared and forwardedto the auditee. The report bypasses the Commission at thistime. The auditee has 30 days to respond to the claims andcan also receive a 15-day extension.

After receiving the auditee response or the 45-day responseperiod has elapsed, the Auditors prepare the Audit Report.This report encompasses the response from the auditee. Thereport is peer-reviewed and forwarded to the Commissionersfor a tally vote or for consideration at an open Commissionmeeting. Upon approval of the Commissioners, the finalreport is provided to the auditee, and a few days later thereport is released to the public.

If a finding in the interim report contains any unresolvedlegal issues, the Audit Division will forward the report toOGC. OGC will analyze the finding and determine legalimplications. After OGC review, OGC will forward its legalanalysis to the Audit Division. If the auditors agree with theOGC analysis, the auditors will incorporate it into theinterim report and forward it to the Commissioners. If Auditdisagrees with the OGC report, Audit will write a separate



cover page and attach it to the front of the interim reportwith its analysis of the issues.

The reports will go to the Commissioners for theirconsideration at an executive session in which they willdiscuss and vote on the interim report. If the Commissionersapprove the report, it will be sent to the auditee. Theauditee then has 30 days (plus a possible 15-day extension)to respond. If the report is not approved, it is reworked forresubmission or it is simply held with no further action andis never publicly released.

After receiving the auditee responses or the 45-day responseperiod has elapsed, the Audit Report is prepared and peer-reviewed. The responses are reviewed with OGC foradequacy and completeness. If unresolved legal issues stillremain at this point, the final report is then forwarded toOGC for analysis (as described above). Once completed,the Audit Report is then forwarded to the Commissioners fora tally vote or for consideration at an open Commissionmeeting. Upon approval by the Commissioners, the officialreport is provided to the auditee. A few days later, thereport is released to the public.

4.2 Audit-For-Cause. 4.2.1 Referral (437(g)) process isdivided into four subprocesses. 4.2.1 Receiving Referralbegins when OGC determines that as a result of its MURinvestigations, some evidence may warrant an audit of a

committee. Depending on the matter, a full-scope auditmay not be necessary.

When OGC determines that a committee should be audited,OGC sends a memo to the Commissioners stating thereasons and recommendation for an audit. Throughinformal methods, the Commissioners will contact the AuditDivision to assess their current availability of resources. IfAudit’s resources are unavailable at this time, the case canbe put on hold until resources can be allocated to the audit.If it is deemed that resources would not be available in atimely manner, the referral is closed.

If the Audit Division has available resources to allocate, theCommissioners vote on the memo. Upon approval of theCommissioners, Audit works with OGC to determine theaudit scope and parameters. They also determine whetherAudit is to perform a full-scope audit or a modified-scopeaudit. It is sometimes possible to perform a modified-scopeaudit in-house without contacting the auditee when there isenough information already gathered between electionreports and what OGC has already obtained. The audit isscheduled with or without contacting the auditee,depending on the scope of the audit. If the auditee is to becontacted, a letter will be sent overnight to the committeeinforming it of the audit and preferable dates that fieldworkis to be performed. The Audit Division will contact thecommittee the following day and confirm the arrangements.



Note: The following steps in the preaudit process may ormay not be performed, depending on the type of audit andvarious circumstances surrounding the audits.

4.2.2 Conducting Preaudit Process begins when the auditorscontact RAD and OGC to discuss any pending itemsconcerning the auditee and any other pending MURs. Theyreview past and present reports to see trends and identifydifferent areas on which they may want to focus moreattention during the audit. Auditors analyze the receipts anddisbursements as disclosed in the reporting and organize theinformation, using different sorts so that they analyze thedata from different perspectives. They reconcile these dataand compare them to the financial data provided by thecandidate/committee.

After completing their analysis in the preaudit process, amodification of the audit program may be necessary to addor delete additional areas that they may need to investigatefurther.

4.2.3 Conducting Fieldwork. A typical audit begins with aconference to explain the purpose of the audit, what theauditee can expect, and also what initial information needsto be provided. The auditee also establishes contacts for theauditors while they are in the field.

The fieldwork is then conducted, using the audit programdeveloped during the preaudit phase. Auditors perform tests

and, depending on the amount of activity, use samplingmethods to test the auditee’s transactions. They gatherevidence and data to keep in the workpapers that will beused to support the findings in the final report.

At the end of the fieldwork, the auditors conduct an exitconference in which they disclose to the candidate anymaterial findings found, according to predeterminedthresholds that are standard for all audits. Generally, theauditee has 10 days to submit a response to the disclosedfindings. The auditee may send the auditors anydocumented evidence, receipts, or reports that may prove afinding incorrect.

If the audit is to be performed in-house with no contact withthe auditee, the fieldwork is conducted at the FEC offices bygathering evidence and data from the information alreadyobtained.

4.2.4 Conducting the Postaudit and Processing AuditReport begins when the auditors complete the fieldwork.Auditors prepare an audit report that discloses the materialfindings or information requested by OGC. This reportencompasses any relevant auditee response to the discussedfindings.

At this time, the auditors complete the audit program andthe indexing of the workpapers. The manager of the team



reviews the workpapers. The completed report, along withthe workpapers, undergoes a peer review.

The report is then given to OGC and is included in the OGCscope of investigation. OGC will use the report in itsanalysis of the MUR. There may be follow-up questionsfrom OGC for further understanding. Once OGC is finishedand the MUR is closed, the MUR and the audit report areopened for public record.

4.3 Presidential Public Funding Program is divided into twosections. Under the FECA, the Commission is required todetermine whether candidates meet certain eligibility criteriaand to certify candidates eligible to receive public funds.The public funding program involves certifying eligibility(primary elections), funding primary elections, fundingconventions, and generating general election grants.

4.3.1 Certifying Presidential Public Funding is divided intothree maps. 4.3.1.1 Certifying Eligibility (PrimaryElections). Primary election candidates seeking matchingfunds submit to the FEC a Letter of Agreements andCertifications (9033 Letter), which is a contract with theGovernment in which a candidate promises to comply withthe law and to submit to an FEC audit in exchange for publicfunding. A candidate’s “threshold submissions” mayaccompany this letter as well.

Threshold submissions include documentation of individualcontributions up to $250 each. The FEC requires participantsin the Presidential public funding program to submitcontribution information through electronic media in orderto expedite the certification and disbursement of matchingfunds. Data Systems makes hardcopy printouts of thethreshold submissions for use in Audit.

Audit conducts a threshold review on all submissions, withzero tolerance for error. The Deputy Assistant Staff Directorof Audit manages this process with temporary staff to

§ Verify that each check is matchable by State, based onstatutory criteria;

§ Verify that contributor information is adequate (i.e.,includes name of contributor, occupation, and correctsignature); and

§ Analyze threshold submissions for any unusual patternsor trends.

Audit staff follow standard review procedures for thresholdsubmissions to verify that the requests meet the necessaryrequirements of matchability.

The threshold review process is repeated again by a differenttemporary staff person, reviewed by the Deputy AssistantStaff Director, and then reviewed again by an availableauditor. In addition, the Deputy Assistant Staff Director



identifies apparent trends, using Data Systems Divisionprintouts that sort the threshold submissions based on avariety of single variables.

If the candidate submits all appropriate documents andmeets the necessary requirements, Audit prepares aneligibility report for the Commissioners. Upon reportapproval, Audit drafts a letter to the Treasury requesting thedisbursement of funds. If the requirements are not met, Auditproactively works with candidates to help them becomeeligible for matching funds. Although this has neveroccurred, if the candidate could not meet the eligibilityrequirements, Audit would issue an ineligibility report,which would be reviewed by OGC for legal compliance andvoted on by the Commission.

4.3.1.2 Certifying Matching Funds (monthly) begins withthe candidate submitting monthly lists of contributions up to$250 from individuals for matching. Presidential candidatesand committees are also required to provide electronicmedia for all matching submissions. The media are reviewedfor completeness and sent to Data Systems to download andfrom which to draw a sample. After eligibility certification,the Audit staff rely on sample committee submissions todetermine the appropriate amount that is matchable. Audituses reject codes to indicate why specific submissionswithin the sample were not matchable. If a sample has toomany unmatchable submissions, the entire request formatching funds could be rejected for that month. Audit

determines how much to certify for Commission approval.Upon Commissioner approval, the FEC issues a letter to theTreasury for funds disbursement.

4.3.1.3 Certifying Matching Funds (conventions) is a grantprocess that takes only a few days and occurs once everyfour years. The Treasurer or President of the conventioncommittee sends to Audit a Request-for-Funds letter. Auditreviews the letter, works with the committee to make anynecessary revisions, and makes a recommendation todisburse funds. The letter is forwarded to OGC for legalanalysis. Audit incorporates any feedback from OGC into areport to the Commission that recommends funding theconvention. The Commission generally votes within 24hours to approve the funding, and Audit drafts and forwardsan approval letter to the Treasury.

4.3.1.4 Certifying Matching Funds (general election) beginswhen the parties nominate the Presidential and VicePresidential candidates. The candidates immediately send asigned Nomination Letter to the FEC. Audit and OGCsimultaneously review the letter to make sure that it satisfiesall of the necessary requirements. Audit will work with thecandidates to quickly identify any information that may havebeen neglected and correct the situation. Once the FECaccepts the letter, Audit prepares a Grant Eligibility Report.The Commission immediately votes to approve the funding,and Audit drafts a letter certifying payment, which is



couriered to the Treasury. This entire process only takes afew hours.

4.3.2 Title 26 Audits is divided into three subprocesses.4.3.2.1 Conducting Preaudit begins when auditors educatethemselves on issues surrounding the candidate and preparefor the fieldwork and is often started before the candidate hasdropped out of the election. Once the candidate hasdropped out, the FEC will contact him or her to schedule theaudit. Auditors contact RAD and OGC to discuss anypending items concerning the auditee, such as Matters UnderReview (MURs). They review past and present reports to seetrends and identify different areas that they may want to focusmore attention on during the audit. They analyze the receiptsand disbursements as disclosed in the election reporting. Thedata are sorted into different categories for different methodsof testing. Auditors reconcile these data and compare them tothe financial data provided by the candidate. Computerizeddata are required for Title 26 audits.

A full-scope audit is always conducted for the Presidentialaudits. After completing their analysis in the preauditprocess, auditors may modify the audit program to addadditional areas that warrant further review.

4.3.2.2 Conducting Fieldwork begins with an entranceconference with the candidate and the FEC auditors. Thisconference explains what the auditee can expect during theaudit and also what initial information the auditors will need.

The auditee also provides the necessary committee contactsfor the FEC auditors while they are in the field.

Auditors conduct an inventory of records, including limitedtesting to determine whether the records are materiallycomplete and in an auditable state. If the auditee has notprovided a material portion of the records, auditors notifythe auditee in writing that the auditee has 30 days to providethe requested records. If at the end of this 30-day period,the records are provided, fieldwork will commence. If therequested records are not provided, the auditors mayrecommend to the Commission that subpoenas for recordsbe authorized, both to the auditee and any other entities inpossession of the relevant records.

The auditors commence fieldwork, using the audit programdeveloped during the preaudit phase. They gather data andperform various tests (generally using sampling methods) onthe transactions of the candidate. They gather evidence anddocument the results in the workpapers that will be used tosupport the findings in the final report.

At the conclusion of fieldwork, auditors conduct an exitconference. At this time, the auditors disclose to thecandidate any material findings found that meet thepredetermined thresholds that are standard for all audits.The auditee has ten days to submit an official response tothe findings and may send the auditors any documented



evidence, receipts, or reports that may prove a findingincorrect.

4.3.2.3 Conducting Post Audit and Processing Audit Reportbegins when the auditors return from the field, and theyprepare the Exit Conference Memorandum that discloses thematerial findings. This report encompasses auditeecomments.

At this time, the audit staff complete the audit program andindex the workpapers for review by the audit manager and asubsequent peer review.

The final memorandum is forwarded to OGC for an informallegal review of the findings. Once this review is complete,the reports are returned to the Audit Division.

The memorandum is presented to the candidate or his or herdesignee(s) at a formal meeting for a formal response to thefindings. Committee officials, the auditors, and OGC alsoattend the meeting. The candidate has 60 days to respondand can obtain an additional 15-day extension, if necessary.Once the Audit Division receives the candidate’s responses,they draft the Audit Report.

Audit forwards the Audit Report to OGC for legal analysis.OGC analyzes the report and makes any necessaryrecommendations. If audit agrees with the OGC analysis,Audit will incorporate the OGC recommendations and

analysis into the report. Audit then forwards the report to theCommissioners. If Audit disagrees with the OGCrecommendations, Audit attaches a separate cover letter tothe final report, explaining the situation and the differencesof opinion. Audit forwards the reports to the Commissionersfor an open session vote under the “Sunshine Laws.” Aninformational copy of the report for consideration by theCommission is forwarded to the candidate prior to the vote.

Multiple sessions may occur before the Commission voteson the recommendations, and the Audit Division and OGCmay be called upon to discuss their recommendations.During these sessions, the Commission may approve, alter,or reject in its entirety the report recommendations forrepayments. Once the Commission renders a vote, thereport is final and is made public. However, if theCommissioners vote against the recommendations forrepayment, the public record will include an explanationconcerning the Commissioners’ votes. No repayments arerequired of the candidate when the Commissioners voteagainst the recommendations. It takes four votes to uphold arepayment determination in an audit report.

When the Commissioners approve a recommendation forrepayment, the candidate has 30 days to petition theCommission for a hearing to argue the repayment assessedagainst him or her. Depending on other significant findingsfound during the audit, a referral may be sent to OGC underthe MUR track.

4.0 Audit Division

4.1 Audit-For-Cause

4.2 Audit-For-Cause: Referral

(437(g))

1/15/99

AUD 1

4.3 PresidentialPublic Funding

Program

4.0 Audit Division

4.1.1 Preparingfor CommissionVote & Notifying

Candidates/Committees

4.1.2 ConductingPre-Audit

4.1.3 ConductingFieldwork

1/15/99

AUD 2

4.1.4 ConductingPost-Audit &

Processing theAudit Report

4.1 Audit-For-Cause

Black box resultsfrom RAD to

Audit

Audit createscover letter &forwards to

Commissionerswith RAD report

As resources areavailable, sendengagement

letter tocommittees fromaudit pool. Call to

schedulefieldwork date.

4.1.1 Preparing for Commission Vote and Notifying Candidates/ Committees

Circulate toCommission

-ers forreview &

vote

Reports areclosed

noSend

engagement to allapproved

auditees. Call toschedulefieldwork.

If auditeerequests delay,schedule audit

outside 6-monthwindow

yes

4.1.2ConductPre-Audit

An approved poolof Non-Candidate

Committees

ApprovedCandidate

Committees

Audit Division

Auditors inquirewithin RAD/OGCfor other issues

Gatherinformation

(MURs)

Review reportedactivity

1/15/99

AUD 3

Analyze bycategories and

set up tocompare to

financial records

4.1.2 Conducting Pre-Audit

Conduct entranceconference

Conductinventory of

auditee records

4.1.3 Conducting Fieldwork

Conduct fullscope audit

Records complete

Withdraw whilerecords are

gathered. Mayinclude

subpoenas.

Conduct exitconference andprovide findingsas documented

4.1.4Conduct

Post-Audit

Reconcilefinancial recordswith electronic

records (ifavailable)

Supplementscope of standard

audit programbased on pre-

audit work

4.1.3ConductFieldwork

4.1.1Prepare

forMeeting


Records incomplete

Wait 10 days forauditee

comments

5.1.2.3Conduct

Review ofAudit

Reports(OGC)

Subpoenas

Audit Division

Prepare interimaudit report whichoutlines findings

1/15/99

AUD 4

Send report toauditee forresponse to

findings

yes

4.1.4 Conducting the Post-Audit and Processing the Audit Report

Discuss findingswith OGC

OGC reviewsreport and

provides legalanalysis of issues

Commissiondiscusses reportand votes in an

ExecutiveSession

Attach covermemo to reportwith explanation

Send report toauditee forresponse to

findings

Wait up to 45days for auditee

response

4.1.3Prepare

forMeeting

Reference newmaterial in report

(peer review)

no

Include OGCanalysis in audit

report

Wait up to 45days for auditee

response

Discussresponses withOGC for legalanalysis, asnecessary

Commissionvotes on report

Release report topublic

Completeindexing;

manager reviewsworkpapers

Peer review ofinterim report

Routinefindings?

Incorporateauditee response

into findings

Does Auditagree with

OGCanalysis?

no

approved

Provide officialreport to auditee

approved

Interim reportnever released

not approved

Report neverreleased

not approved

Audit Division

4.2.1 ReceivingReferral

4.2.2 ConductingPre-Audit

4.2.3 ConductingFieldwork

1/15/99

AUD 5

4.2.4 ConductingPost-Audit andProcessing theAudit Report

4.2 Audit-For-Cause: Referral (437(g))

Audit Division

OGC decidescommittee should

be audited

1/15/99

AUD 6

Close case orcontinue without

auditno

4.2.1 Receiving Referral

Work with OGCto determine

scope/parameters of

audit

Schedule audit

MUR - Inprocess

from OGC

yes

OGC sendsCommissioners

a memorecommending

audit

Commissionersinformally notifyAudit to assess

current resources

Commission-ers vote to

proceed withaudit?

Audit Div. may hold off untilresources become available


4.2.2 Conducting Pre-Audit

4.2.1ReceiveReferral

Inquire withinRAD/OGC forother issues

Gatherinformation

(MURs)


set up tocompare to

financial records


records (ifavailable)


(Varies depending on scope of audit)

Audit Division

1/15/99

AUD 7




Does Auditneed to

contact theauditee?

yes

Commence full orlimited scope

audit


Wait 10 Days forauditee to

attempt to proveFEC findings

incorrect

Perform fieldworkin-house

no

4.2.4Conduct

Post-Audit

4.2.4 Conducting Post-Audit and Processing Audit Report


Prepare auditreport and layoutfindings for OGC

Completeindexing; audit

managerperforms reviewof workpapers

Conduct peerreview of audit

report

Forward auditreport to OGC

OGC continueswith MUR

OGC closes MUROpen MUR andaudit report to

public

Audit Division

4.3.2.1Conducting Pre-

Audit

4.3.2.2ConductingFieldwork

4.3.2.3Conducting Post-

Audit andProcessing Audit

Report

1/15/99

AUD 8

4.3 Presidential Public Funding Program

An audit of all presidential candidates receiving public funds is mandated bystatute. The FEC has an internal policy that all presidential audits must be

completed within two years of the general election.

4.3.2 Title 26 Audits

4.3.1 Presidential Public Funding Certification

4.3.1.1 CertifyingEligibility

4.3.1.2 CertifyingMatching Funds

(Monthly)

4.3.1.3 CertifyingMatching Funds(Conventions)

4.3.1.4 CertifyingMatching Funds

(GeneralElection)

Audit Division

Candidatesubmits 9033

Letter

1/15/99

AUD 9

4.3.1.1 Certifying Eligibility (Primary Elections)

Audit reviews forcompleteness

Press Office putsletter on public

record andnotifies

Commissioners

OGC reviewsletter

Audit performsinitial review forgood order andinclusion of all

documents

Thresholdsubmission

Has all therequired

informationbeen

submitted?

Prepare eligibilityreport for

Commissioners

Informationis complete

Moreinformationis needed

Have re-quirementsbeen met?

yesCommissioner

voteDraft letter to

Treasury

Treasuryreceives letter

and funds money

Informally workwith candidate to

meetrequirements4

Issue IneligibilityReport (This hasnever happened)

OGC reviewIneligibility Report

Commissionvotes on

Ineligibility Report

no

4.3.1 Certifying Presidential Public Funding

See5.1.2.1A

OGCProcess

Verify each checkis matcheable by

state2

Analyze sorts forany unusual

patterns

Verify informationin system is

correct - name ofcontributor,occupation,signature3

Run through this process three times (twicewith temps, once with an Audit manager)

Threshold Review

1 Regulations set a deadline of 15 days to determine eligibility2 Normally check 21-22 states. One pass takes a couple of hours per state3 Logical checks based on review of the documents and electronic records provided4This is an opportunity for the candidate to appeal the decision and demonstrate he or she has met the requirements

Audit Division

1/15/99

AUD 10

4.3.1.2 Certifying Matching Funds (Primary Elections)

Monthly

Candidatesubmits tape or

disk ofalphabetized list

of checks

Review forcompleteness

Send to DataSystems todownload

Data Systemsdraws a sample

Review sample

Produce memofor

Commissionerswith

recommendationon amount to

certify

Determineamount

matcheable

Commissionapproves full

amount

Report toTreasury for

disbursement

Audit Division

1/15/99

AUD 11

4.3.1.3 Certifying Matching Funds (Conventions)

Committeeprepares Request

for Funds letterand sends to

Audit

Review letter

1 Treasury handles the wire transfer and the committee gets the money the summer before the convention.

4.3.1.4 Certifying Matching Funds (General Election)1

Candidate sendssigned

nomination letterto FEC

Review forrequirements

Prepare GrantEligibility Report

Commissionvotes

immediately

OGC review

yes

Legal review byGeneral Counsel

Prepare report toCommission withrecommendation

to fundcommittee

Commission tallyvotes within 24

hours

Draft letter toTreasury

ObtainChairmen’ssignature

Send report toTreasury1

Send back forrevisions

acceptable

Nominationletter

accepted?

Draft letter toTreasury

Chairman signsletter

Courier letter toTreasury for

payment

1 Process only takes a couple of hours to complete.

Analyze request

no

Audit Division

1/15/99

AUD 12

4.3.2.1 Conducting Pre-Audit

4.3.2.2ConductFieldwork

FEC staff trackscandidates and

begins schedulingformer candidateaudits (primarylosers and drop

outs)

Inquire withinRAD/OGC forother issues

Gatherinformation

(MURs)


set up tocompare to

financial records


records

Review reportedactivity

Supplementscope of standard

audit programbased on pre-

audit work


Commence fullscope audit


4.3.2.3Conduct

Post-Audit

4.3.2.1ConductPre-Audit

Wait 10 days forauditee

comments


4.3.2 Title 26 Audit

Audit Division

Create exitconference

memo and auditmanager reviews

1/15/99

AUD 13

4.3.2.3 Conducting Post-Audit and Processing Audit Report

OGC reviewsreport and

provides legalanalysis of issues

Commissiondiscusses report

and votes in opensession

Attach covermemo to reportwith explanation

Send report tocandidate with

Commissioners’explanation

attached

Wait up to 75days for

candidateresponse

4.3.2.2ConductFieldwork

No fines orpenaltiesassessed

Include OGCanalysis in audit

report

Refer to OGCdue to significant

findings (MURtrack)

Wait 30 days forcandidate topetition for

hearing from dateof issued report

Commissionvotes on report

OGC reviewsmemo

Send memo tocandidate

Incorporatecandidate

response intoaudit report

Does Auditagree with

OGCanalysis?

no

yes

Dis-approval

Approval

Conduct hearingon repayment

issues

Uphold or reducerepayments

OGC preparesStatement of

Reason (restatesissues)

Candidate paysTreasury

Commissionersdisapprove and

assess nopenalties

Candidate files incourt



5.0 Office of the General Counsel

Process Customers

Internal: Other FEC Offices

External: Filers, Public


The Office of the General Counsel is divided into fourdivisions: Public Financing, Ethics, and Special Projects;Policy; Enforcement; and Litigation. High-level process mapshave been drawn for each.

5.1 Public Financing, Ethics, and Special Projects (PFESP) isresponsible for two mapped processes and five areas ofresponsibility not mapped: reviewing debt settlements,administrative terminations, ethics, Title 2 audits, andmanaging special projects. These latter processes were notmapped either because they represent a small portion of thetotal workload or because they typically are not processdriven.

5.1.1 Prosecuting Violations begins when Audit refers a caseor Enforcement forwards a matter to PFESP. [See the processmap for a description of the process following this sectin.]

Within 5.1.2 Conducting Legal Review of Public Financing,several subprocesses exist.

5.1.2.1A Reviewing Eligibility for Matching Funds beginswhen PFESP receives a request from the Audit Division toreview candidate’s Letter of Agreements and Certifications(9033 Letter) for legal accuracy. This letter is a contract withthe Government in which a candidate promises to complywith the law and to submit to an FEC audit in exchange forpublic funding. PFESP conducts a legal review, generates areport concerning its review, and forwards the report to theAssociate General Counsel for review and approval. If theAssociate General Counsel does not approve the report, theattorney who drafted the report rereviews the legal analysis,incorporates edits into the report, and resubmits the editedreport for review and approval. If the Associate GeneralCounsel approves the report, PFESP sends comments toAudit. Audit sends the Commissioners the recommendation,which the Commissioners consider. If approved, PFESPsends notification to the candidate.

5.1.2.1B Reviewing an Ineligibility Determination AfterCandidate Has Been Determined Eligible begins after Auditinitially determines that a candidate is eligible for matchingfunds, but then finds the candidate to be ineligible by the 10percent rule. In addition, candidates are no longer eligiblefor public funds after they withdraw from the race. A PFESPattorney reviews Audit’s determination, drafts a memoconcerning date of ineligibility, and forwards the draft to the



Associate General Counsel for review. If the AssociateGeneral Counsel does not approve the memo, then the staffattorney redrafts the memo, incorporating the comments,and resubmits the memo for review. If the Associate GeneralCounsel approves the memo, the attorney sends the memoto the Commissioners for consideration and a tally vote. Ifthe Commissioners vote to approve the date of ineligibility,PFESP notifies the candidate of the Commissioners’ decision.If the Commissioners do not agree with the date ofineligibility, the Commissioners return the memo to PFESPfor revision. If the candidate challenges the ineligibility datedetermination, the process repeats for a Final Determination.

5.1.2.1C Reviewing Ineligibility Prior to Candidate BeingDetermined Eligible begins when PFESP receives a requestfrom Audit to conduct a legal review of a 9033 Letter. PFESPconducts an analysis and submits it to the General Counselfor review and approval. If the General Counsel does notapproves the analysis, the attorney reconsiders and redraftshis or her analysis and resubmits the document to theGeneral Counsel for approval. If the General Counselapproves the analysis, PSESP forwards the review to Auditfor comment. Using Audit’s comments, PSESP drafts a memoto the Commissioners concerning the legal review andforwards the memo to the General Counsel for review.

Upon approval, PFESP sends the memo to theCommissioners, who review the memo. If approved, PFESPsends a Statement of Reason (SOR) notification to the

candidate. The candidate reviews the SOR notification andresponds to the findings. PFESP reviews the response andforwards it to Audit for comment. PFESP incorporates Audit’scomments into the Final Determination/SOR draft. TheGeneral Counsel reviews the draft, and upon his or herapproval, PFESP sends the memo to the Commissioners forconsideration. If the Commissioners approve, PFESP notifiesthe candidate of the Commissioners’ decision. If thecandidate is determined to be eligible for funds, then theprocess ends. If the candidate is determined to be ineligiblefor funds, then the candidate can appeal the determinationto the Court of Appeals.

5.1.2.2 Reviewing Entitlement Recommendations beginswhen PFESP receives a request from Audit to review anentitlement determination. PFESP conducts a legal review ofthe entitlement determination and drafts a memo of findings.The General Counsel reviews the memo and, if he or shedoes not approve, returns the draft with comments to thedrafting attorney. The attorney incorporates his or hercomments into the new draft memo and resubmits it forapproval. If the General Counsel approves the memo, PFESPsends the memo to Audit. Taking into account the legalreview, Audit makes a recommendation to theCommissioners concerning initial determination ofentitlement, and the Commissioners consider therecommendation. No matter the Commissioners’ decision,PFESP notifies the candidate of the decision and waits for aresponse. PFESP receives the candidate’s response and



forwards the document to Audit for comment. Audit reviewsthe response and sends its comments to PFESP, whoincorporates them into the Final DeterminationRecommendation draft. The General Counsel reviews andapproves the draft, and PFESP sends the memo to theCommissioners for consideration. No matter theCommissioners’ decision, PFESP notifies the candidate.Based on the Commissioners’ determination, the candidatecan either petition for a rehearing or file an appeal in theCourt of Appeals.

5.1.2.3 Conducting Legal Review of Audit Reports canbegin during the audit fieldwork phase when Audit asksPFESP to issue subpoenas for missing documentation. BeforeAudit’s exit conference with the auditee, Audit sends the ExitConference Memorandum (ECM) to PFESP for legal review.The committee responds to issues raised at the exitinterview, which Audit may include in its report. Auditissues the audit report, which PFESP reviews and forwards tothe General Counsel for review. Upon General Counselapproval, PFESP issues and forwards to Audit a memoconcerning the review. In addition, PFESP sends the memoand packet of information concerning the audit report to theGeneral Counsel for review. If the General Counsel does notapprove the memo and/or packet, he or she returns them toPFESP for revision. PFESP incorporates the GeneralCounsel’s feedback and resubmits the packet for GeneralCounsel approval. If the General Counsel approves, PFESPsends the memo to Audit. Throughout the rest of the audit

process, PFESP provides continuous support to Audit. TheCommissioners issue the audit report and send the reportand Determination of Repayment to the committee. If thecommittee repays the money owed to the Commission, theprocess ends. If the committee does not pay the moneyowed to the Commission, the repayment process begins.

5.1.2.4 Reviewing Repayment Recommendation beginswhen a committee requests an Administrative Review andHearing concerning the amount of money owed to theCommission. PFESP notifies Audit of the request and sends amemo to the Commissioners to schedule the hearing. PFESPcreates an informational Briefing Memo for theCommissioners, and FEC holds a public meeting concerningthe repayment issue. If the committee submits moreinformation after the hearing, PFESP reviews it and providesthe committee with transcripts of the hearing and theircomments. PFESP drafts a Statement of Reason (SOR)incorporating Audit’s comments and has Litigation and theGeneral Counsel review it. Upon approval, PFESP sends theCommissioners the SOR for review. If the Commissioners donot approve the SOR, PFESP rewrites the SOR, including theCommissioners’ comments, and resubmits the revised SORto the General Counsel for review. If the Commissionersapprove the SOR, PFESP generates a Notification Letterconcerning the Commissioners’ decision on repayment andsends it to the committee. Depending on the decision, thecommittee can either petition for a Rehearing or appeal to



the Court of Appeals. Pending the appeal, the debt owed theCommission is stayed.

5.2 Policy is responsible for essentially four mappedprocesses. In addition, this Division is responsible forconducting legal review of non-FECA regulations; however,this process was not mapped because it represents a smallportion of the total workload or because it typically is notprocess driven.

5.2.1 Rendering Advisory Opinions begins when arequester, such as a committee or corporation requests theFEC to issue an advisory opinion on a particular topic. Therequest is routed to the OGC Policy Division, whichevaluates the issue for jurisdictional requirements. If the FECdoes not have jurisdiction, then the FEC declines to issue anadvisory opinion and informs the requester of the decision. Ifthe issue passes legal requirements, Policy assigns the issuean Advisory Opinion Request (AOR) number and sends acopy of the request for Public Records. An attorney isassigned to research and write the advisory opinion. Theassigned attorney researches the issues and clarifies with therequester whether the request is a formal or informal one. Ifthe requester does not respond to the attorney’s request forinformation, the attorney attempts to contact the requesteragain.

If the requester withdraws his or her request for an advisoryopinion, the process ends. If the requester does not

withdraw his or her request, the attorney prepares a whitedraft of the advisory opinion and forwards the draft to theAssociate General Counsel for review. Upon approval, theattorney e-mails the approved draft for comment to seniorGeneral Counsel staff, the General Counsel, and theCommissioners. These comments are incorporated into thewhite draft, and the attorney submits an agenda proposaland schedules a Sunshine Act notice to appear in the publicrecord. The Associate General Counsel and the GeneralCounsel review the draft report. Once approved, theattorney forwards a hardcopy of the blue draft to theCommission Secretary. The Commissioners review the draftand submit comments to Policy. Meanwhile, Policy makesthe agenda proposal public for comment. The attorneyevaluates and incorporates public comments into the draftand determines whether to counter comments or incorporatethem into the document.

The Commissioners debate and vote on the draft advisoryopinion. If the Commissioners do not vote to approve thedraft, then Policy issues an AOR Closure Letter. If theCommissioners vote to approve the draft, then the attorneyreformats the document and forwards it to the CommissionChairman for signature. Once signed, the attorney sends theadvisory opinion to the requester and releases it to thepublic via the Public Records office. Upon receiving theadvisory opinion, the requester can either take no action orask the FEC to reconsider the issue. The Commissioners canalso ask OGC to reconsider the opinion.



5.2.1.1 Reconsideration can begin when either the requesteror a Commissioner submits a Request for Reconsiderationwithin 30 days of the Commission’s decision. In response,Policy drafts both a Memorandum to Reconsider theAdvisory Opinion and a Reconsideration Opinion, whichthe Associate General Counsel and General Counsel review.Following their review, the attorney forwards theReconsideration Opinion to the Commissioners, who debateit in an open session. At this point, the process feeds into theAdvisory Opinion process at the “ Commissioners debatesand votes” step.

5.2.2 Reviewing Regulations can begin one of three ways:(1) the Commissioners can direct OGC to draft a regulation;(2) an external petitioner can petition to repeal, modify, oradd a new regulation; or (3) an internal office, such asLitigation or Audit, can petition a regulation.

If the Commissioners direct OGC to repeal, modify or add anew regulation, then Policy drafts a Course− of− Actiondocument. If the request comes from an external petitioner,then Policy issues a Public Notice of Availability, receivesand evaluates comments from the public, and generates aCourse-of-Action document. If an internal petitioner beginsthe process, Policy generates a memo to Recommend RuleMaking Process, informs the Commissioners through amemo, and generates a Course-of-Action document.

In the Course-of-Action document, Policy recommends tothe Commissioners one of three alternatives: (1) OGC shouldnot proceed with rule making; (2) OGC should issue anAdvance Notice of Proposed Rule Making; or (3) OGCshould issue a Notice of Proposed Rule Making.

If Policy recommends not to proceed with rule making, theCommissioners debate and discuss this recommendation. Ifthe Commissioners vote to accept the recommendation, theprocess ends. If the Commissioners vote not to accept therecommendation, then Policy issues a Notice of ProposedRule Making.

If Policy recommends to issue either an Advanced Notice ofRule Making or a Notice of Proposed Rule Making, theCommissioners debate, discuss, and vote whether toapprove the recommendation. If they vote to approve theNotice, OGC publishes the Notice of Rule Making forcomment and offers a proposed rule for public comment(30− 60 days). Policy incorporates public comments into theproposed rule and decides whether a public hearing on theproposed rule is necessary. If a hearing is not necessary, theproposed rule is sent to the Commissioners for a vote toapprove, modify, or reject the rule. If the Commissionersvote to reject the rule, the process ends. If theCommissioners vote to modify the rule, the processcontinues with the “Formulate Draft/Final Rule” activity. Ifthe Commissioners vote to approve the rule, the rule is made



public and sent to Congress 30 legislative days before itseffective date.

If a hearing is necessary, Policy sets a hearing date, holds apublic hearing, evaluates hearing testimony, andincorporates hearing data into the draft rule. The AssociateGeneral Counsel and the General Counsel review andapprove the draft rule, and once approved, OGC presentsthe revised draft rule to the Commissioners. The rule is madepublic, and the Commissioners debate and vote whether toapprove, modify, or reject the rule. If the Commissionersreject the draft rule, the process ends. If the Commissionersvote to modify the draft rule, the process continues with the“Formulate Draft/Final Rule” activity. If the Commissionersvote to approve the draft rule, the rule is made public andsent to Congress 30 legislative days before it becomeseffective.

5.2.3 Conducting Legal Review of FECA documents beginswith an internal request to Policy to review FECpublications. Publications include the Record, the AnnualReport, and the Guide and Brochure series. Policy assigns tothe publication a legal review number and a staff attorney.Once the attorney reviews the draft of the publication, theAssociate General Counsel reviews the attorney’s comments.Upon approval, Policy returns the publication draft withcomments to the editor for editing. As the FEC Record andother publications often have multiple drafts, this processwould be repeated as many times as necessary.

5.3 Enforcement. 5.3.1 Enforcement Process is a series ofcomplicated legal processes with so many paths that to try tocommit the process to a narrative would not add value tothis analysis. Therefore, please refer to the process maps fora high-level description of enforcement activities.

5.3.2 Cases on the Central Enforcement Docket (CED) areeither internally or externally generated. If the cases areinternally generated, their sources are a Directive 6, a RADreferral, sua sponte, or an outside agency referral. Oncereceived, where appropriate, Enforcement assigns each casea pre-Matter Under Review (MUR) number.

If the complaint is externally generated, Enforcementreviews the complaint for statutory criteria and submitsissues to the special assistant who reviews for jurisdiction. Ifthe issues do not meet the criteria, Enforcement notifies thecomplainant and respondents of the rejection of thecomplaint. If the complainant resubmits the complaint,Enforcement resubmits the issues to special assistant. If theissues meet the criteria, Enforcement assigns the complaint aMUR number and sends a copy of the MUR to theCommissioners for information.

No matter how the matter was generated, Enforcementcreates files, including a permanent file, for the CED leaderand staff and assigns a paralegal to process the matter. Theparalegal opens the case on the Enforcement Priority System(EPS) and MUR Tracking System (MTS), inputs the basic case



data (i.e., statute area affected), and prepares the factsummary of the case. Meanwhile, the assigned paralegalconducts a preliminary review of legal issues, generates a listof respondents, sends the list to the CED leader, andincorporates edits as necessary. If there is an overlap with anaudit, then Enforcement refers the complaint to PFESP.Otherwise, the process continues.

For complaint-generated matters only, CED generates andmails letters to the respondent. The respondent can requestan extension, and CED can grant extensions up to 30 days.Extensions greater than 30 days require Commissionerapproval. Enforcement receives all requests for extension.

For all cases, CED rates the case on EPS, creates an EPSrating sheet, and circulates the sheet to the Commissioners.If the case rates below the threshold, Enforcement holds thecase in CED, and the paralegal prepares a narrativesummary for each case. The CED leader drafts a periodicGeneral Counsel (GC) Report recommending dismissal,which the Associate General Counsel reviews. When theAssociate General Counsel approves the report, he or sheforwards the report to the General Counsel, who reviews thereport. If the General Counsel approves the report, CEDcirculates the GC report to the Commissioners. If theCommissioners approve the GC report on a tally vote, CEDnotifies complainants and respondents. CED closes the casein EPS and MTS, enters the case in the MUR coding system,

and transfers the files to the Freedom of Information Actsection. At this point, Defensive Litigation can occur.

If the Commissioners do not approve the General Counselreport on a tally vote, the Commissioners discuss objectionswith Enforcement. Enforcement generates and circulates anObjection Memo and schedules and participates in aCommission Executive Session. If the Commissionersapprove the report, CED notifies complainants andrespondents. CED closes the case in EPS and MTS, enters thecase in the MUR coding system, and transfers the files to theFreedom of Information Act section. At this point, thedefendant can sue the FEC, which would trigger theDefensive Litigation process.

If the Commissioners do not approve the General Counselrecommendation, Enforcement holds the MUR(s) in CED.

If the case rates above the threshold, CED compiles,prepares, and circulates summary information on CED casesfor the monthly CED meeting. Included in these data areteam leader input on staff availability for cases and teamleader reports on case load and projects. Enforcement holdsthe monthly meeting during which cases and workload arereviewed, staff availability is identified, and new cases areactivated and assigned to staff attorneys.

Cases that are not activated are left in CED. If the case isactivated, paralegals update the systems and pull case files



and the master file. They conduct a page-by-pagecomparison of the case file information with the master fileinformation; return the master file; and send other copies toteam leader, staff attorney, and investigator. In addition,CED creates an EPS Status Report, which is forwarded to theAssociate General Counsel for review. When the report isapproved, it is placed on the agenda for Commissionerreview. The Commissioners can decide to pursue or notpursue the cases.

5.3.3 Statements of Reason process begins when theCommissioners fail to approve the General Counsel’srecommendation to go forward with a case. Enforcementdrafts a Statement of Reasons with a cover memo if the votewas a majority one. If the vote was a split one, thenEnforcement writes only a cover memo. The AssistantGeneral Counsel reviews the report and memo. Once theAssistant General Counsel approves the documents, theAssociate General Counsel reviews them. Once theAssociate General Counsel approves the documents, theGeneral Counsel reviews and signs them and sends them tothe Commission. The Commission issues a Final Statementof Reasons, which OGC files and sends to complainantwhen case closes.

5.3.4 Dismissing Low Rated and Stale Cases begins when acase is identified for closing. CED generates a reportrecommending closing, which is reviewed by the CEDLeader. When the CED Leader approves the report, the

Associate General Counsel reviews the report. When theAssociate General Counsel approves the report, the GeneralCounsel reviews the report. When the General Counselapproves the report, the report is sent to the Commission fora tally vote. If the Commission votes to close the case, CEDcloses the case, inputs case data into the system, notifies allrespondents and complainant of the decision, and sends thecase file to FOIA. If the Commission decides not to close thecase, it is returned to CED.

5.3.5 Maintaining the Permanent File process begins whenCED receives a document relating to a MUR. CED matchesthe document with the MUR and determines to whom thecases is assigned. CED generates four copies, returns theoriginal to permanent administrative file, and distributesother copies.

5.3.6 Coordinating Executive Session Agenda processbegins when a report is sent to CED for circulation and isforwarded to the Office of the Secretary to the Commission.If no Commissioner objects, then the Secretary’s Officeprepares and CED distributes a certification of theCommission vote. If any Commissioner objects, CEDdistributes vote sheets showing objections, prepares draft ofagenda for comment, and circulates agenda to participants.CED revises the agenda as necessary, and sends the finalagenda to the Office of the Secretary to the Commission.



5.3.7 Tracking Civil Penalties begins when CED receivesfrom Administration a copy of a check, which is consideredpart of the case file. Enforcement updates the Civil PenaltyTracking database and generates a two-way memo toAdministration regarding disposition of the check. Then CEDdistributes copies of the two-way memo and check.

5.3.8 Archiving beings when a case file has been held for acertain period of time. CED collects files and stages them forretirement in the National Archives. Staff packs, indexes,and labels boxes for archiving. CED sends indexes toAdministration to schedule pickup, and Administrationprovides accession number to the docket. CED adds theaccession numbers to the labels, seals the boxes, and sendsthem to Administration to ship.

5.4 Litigation is responsible for offensive and defensivelitigation processes. However, these processes are verycomplicated with so many paths that to try to commit theprocesses to paper would not add value to this analysis.

5.0 Office of General Counsel

5.1 PublicFinancing, Ethics

and SpecialProjects

5.2 Enforcement 5.3 Litigation 5.4 Policy

5.1 Public Financing, Ethics and Special Projects

5.1.1 ProsecutingViolations

5.1.2 ConductingLegal Review ofPublic Financing

5.2 Policy

5.2.1 RenderingAdvisoryOpinions

5.2.2 ReviewingRegulations

5.2.3 ConductingLegal Review of

FECA

1/15/99

OGC 1

5.3 Enforcement

5.3.1Enforcement

5.3.2 CentralEnforcement

Docket

5.3.3 Statementof Reason

5.3.4 DismissingLow Rated and

Stale Cases

5.4 Litigation

OffensiveLitigation

DefensiveLitigation

5.3.6Coordinating

ExecutiveSession Agenda

5.3.5 Maintainingthe Permanent

File

5.3.7 TrackingCivil Penalties

5.3.8 Archiving

Audit refers case

Enforcementforwards case

Rate case using EPSII

Draft Rating SheetObtain Associate

General Counsel’ssignature

Circulate RatingSheet to

Commissioners

Draft report toCommissioners on

low rated cases

Begin prosecutingviolations

General Counselapproves and signs

report

Circulate report toCommissioners

Hold inactive Tier 1or 2 cases onPFESP docket

Activate case

Initiate enforcementproceedings

Determine case isstale. Draft report toCommissioners on

determination.

Commissionersconsider report

DoCommissionersapprove report?

Notify respondents

Close caseLeave case onPFESP docket

Yes

No

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5.1 PFESP

5.1.1 Prosecuting Violations

OGC 2

Receive request fromAudit to review 9033

letterConduct legal review

Does AGCapprove report?

Associate GeneralCounsel (AGC)reviews report

Generate report

No

Send comments toAudit

Yes

OGC 35.1 PFESP

5.1.2.1A Reviewing Eligibility for Matching Funds

Audit sendsrecommendation to

Commissioners

Commissionersconsider

recommendation(tally vote)

If Commissionersapprove

recommendation,notify candidate

AssociateGeneralCounsel

reviews memo

Audit withdrawscandidate’s eligibilityfor matching fundsunder the 10% rule

or when thecandidate withdraws

from race

Draft memo toCommissioners ondate of ineligibility

Upon approval, sendmemo to

Commissioners

Commissionersconsider memo (tally

vote)

Notify candidate ofdecision1

DoCommissioners

approve?

Return to OGC forrevision

1If Candidate challenges ineligibility date determination, the process is followed again for finaldetermination after receipt of challenge.

Yes

No

5.1.2.1B Reviewing an Ineligibility Determination After Candidate Has Been Determined Eligible

5.1.2.1 Reviewing Eligibility for Matching Funds

Disapprove

Approve

1/15/99

5.1.2 Conducting Legal Review of Public Financing

Receive request toconduct legal reviewof 9033 Letter from

Audit

Conduct legal review Send memo to AuditDraft memo toCommissioners

Send memo toCommissioners

Commissionersconsiders memo

(agenda)

Commissionersapprove?

Send Statement ofReason (SOR)notification to

candidate

Receive candidateresponse

Review responseSend response to

Audit

Incorporatecomments from Audit

Draft FinalDetermination/SOR

Draft memo toCommissioners

DoCommissioners

approve?

Send notification tocandidate

Is candidateeligible?

EndYes

If determinedineligible, candidate

can appeal toCourt of Appeals

No

Approve

Approve

yes

Yes Yes

OGC 4

5.1.2.1C Reviewing Ineligibility Prior to Candidate Being Determined Eligible

5.1.2.1 Determining Eligibility for Matching Funds

General Counselreviews analysis

Disapprove

General Counselreviews memo

General Counselreviews Final

Determination/SOR

1/15/99

Receive request fromAudit to conductlegal review of

Entitlement memo

Conduct legal review,draft memo of

findingsSend memo to Audit

Audit recommends toCommissioners initial

determination ofentitlement

Audit forwardscomments to OGC

Forward candidateresponse to Audit

Candidate respondsto OGC’s findings

and Commissioners’decision

Notify candidate ofdecision

Commissionersconsider

recommendation

Send memo toCommissioners

Notify candidate ofdecision

Commissionersconsider memo

Draft FinalDetermination

Recommendation

Candidate petitionsfor rehearing

Candidate appealsCommissioners’

decision to Court ofAppeals

Approves

5.1.2.2 Reviewing Entitlement Recommendations


General Counselreviews analysis

Disapproves

Commissionersrender decision onrecommendation

Commissionersrender decision onrecommendation

General Counselconsiders

recommendation

OGC 5

1/15/99

Receive audit reportfrom Audit

Committee respondsto issues raised in

exit conference

Audit conducts exitconference

Issue subpoenas(during fieldwork)

Generate memo toAudit on legal review

Conduct legal reviewof report

General Counselreviews memo

Incorporate/addressGeneral Counsel’s

comments

Send packet toPFESP for

modification

Send memo andaccompanying support

to Audit

Provide continuoussupport to Audit

Commissioners issueaudit report

Send report and re-payment

determination tocommittee

Does committeerepay?

Yes

No

Approves

Review ExitConference

Memorandum (ECM)

ECM From AuditLegal ReviewMeetings with AuditComments by E-mail

End

5.1.2.3 Conducting Legal Review of Audit Reports



(Audit)

Disapproves

5.1.2.4Review

Repayment

OGC 6

1/15/99

Conduct legal reviewof report and forwardto General Counsel

for review andapproval

Committee requestsan Administrative

Review and HearingHold public hearing

Create briefingmemo (informational)

for theCommissioners

Send a memo to theCommissioners toschedule hearing

Send committee’srequest to Audit

Review informationand provide

transcripts andcomments to

Commissioners

If necessary,committees submitmore information

Incorporate Audit’scomments

Generate NotificationLetter

Committee petitionsfor Rehearing

Litigation reviewsSOR

General Counselreviews SOR

Send SOR toCommissioners

DoCommissioners

approve?

Prepare Statement ofReason (SOR)

Incorporate comments

No

Yes

Committee petitionsfor review by Court of

Appeals. Debt isstayed pending

appeal.

5.1.2.4 Reviewing Repayment Recommendation

5.1.2 Conducting Legal Review of Public Financing OGC 7

1/15/99

Requester:Committee,Corporation,

etc.

Issue OGC - PolicyDivision

Evaluate issue forjurisdictionalrequirements

Does issuemeet legal

requirements?

Generateresponse torequester

no

Assign AORnumber

yesSend copy of

request to PublicRecords

Assign AO toattorneys

Research opinion

Clarify withrequester

whether requestis formal or

informal

Prepare whitedraft with Assoc.General Counsel

review

E-mail whitedraft for commentto Sr. GC Staff,

General Counsel,Commissioners

Incorporate input/internal

comments intodraft

Submit agendaproposal

AssociateGeneral Counsel

reviews draft

General Counselreviews draft

Forward hardcopy of blue draftto Commission

Secretary

Commissionersreview & submit

comments

OGC makesagenda proposal

public forcomment

Evaluate/incorporate

comments fromCommissioners

and publiccomments

Determinewhether torespond to

comments ortake back draft to

further edit

Commissionersdebate and vote

on draft

DoCommission-ers vote to

approveopinion?

Reformatdocument

yes

Draft AORclosure letter

no

ScheduleSunshine Act

Notice to appearin public record

A

AFollow-up if no

response

Doesrequesterwithdrawrequest?

Endyes

no

B

B C

D

5.2.1 Rendering Advisory Opinions

5.2 Policy Division OGC 8

1/15/99

Circulate to publicvia PublicRecords

Requester

Take no action

5.2.1.1Recon-sider-ation

Send documentto requester

Chairman ofCommission

signs documentC

5.2.1 Rendering Advisory Opinions, continued

5.2 Policy Division

Requester

5.4.1AdvisoryOpinion

Commission-er

Submit Requestfor

Reconsiderationwithin 30 days of

decision

Generate memoto reconsider AO

PrepareReconsideration

Opinion


reviewsReconsideration

Opinion

General Counselreviews

ReconsiderationOpinion

ForwardReconsideration

Opinion toCommissioners

DebateReconsiderationOpinion in open

session

D inAdvisoryOpinion

map

5.2.1.1 Reconsideration

OGC 9

1/15/99

OGC 10

1/15/99

ExternalPetitioner

Petition to Repeal, Modifyor Add New Regulation

DRAFT

OGC - PolicyDivision

Issue PublicNotice of

Availability

InternalPetition

(Litigation,Audit, etc.)

InformCommissionersthrough memo

Receive &evaluate

comments frompublic

Generate Courseof Actiondocument

Do not proceedwith rulemaking

Proceed withAdvance Notice

of ProposedRulemaking

Proceed withNotice ofProposed

Rulemaking

A

B

C

A

B

C

Commissionersdebate & discuss

No

Commissionersdebate and

discuss

Commissionersvote to approve

Publish Notice ofRulemaking for

comment

Incorporate publiccomments into

rule

Formulate draft/final rule


and GeneralCounsel review

and approve rule

Commissionersdebate and make

decision public

Commissioners vote toapprove,modify,

reject rule

DD

Approve

Commissiondirective to

OGC

Generate memoto recommend

rule makingprocess


acceptrecommend

ation?

EndYes

Offer proposedrule for public

comment (30 - 60days)

Set hearing date

Conduct publichearing

Evaluate hearingtestimony

Is a publichearing

necessary?Yes

No

E

Reject

E

ModifyMake rule public

and send toCongress 30

legislative daysbefore effective

date

End

5.2.1 Reviewing Regulations

5.2 Policy Division

5.2.3 Conducting Legal Review of Federal Election Commission Act

5.2 Policy Division OGC 11

1/15/99

Internalrequest to

review FECpublications1

Assign LegalReview number

and staff toreview draft of

publication


reviewscomments

Return withcomments to

editor ofpublication2

Draft ofpublication

PolicyDivision

Internalrequester

1Publications include Record, Annual Report and Guide and Brochure series.2 FEC Record and other publications often have multiple drafts and if so, would go through the cycle multiple times.

Staff reviewpublication and

make comments

If multiple drafts

5.3.1 Enforcement Process

5.3 Enforcement Division

Internallygenerated matter

Directive 6

RAD referral

Outside agencyreferral

"Sua Sponte"

Assign MURnumber

Review complaintfor statutory

criteria

Notifycomplainant and

respondents

Receive externalcomplaint

Doescomplaint

meetcriteria?

Send to CentralEnforcementDocket (begin

CED 5.3.2)

Draft first GeneralCounsel Report1

Send significantcases to senior

staff for commentand approval

Assistant GeneralCounsel reviews

report

Revise reportbased on

comments andprepare final

package

B

A

1 First GC Report recommends a Reason to Believe (RTB) orno RTB where appropriate (Tier IV and some Tier II cases)

OGC 12

1/15/99

5.3.1 Enforcement Process,continued



reviews finalpackage and

report

Assistant GeneralCounsel reviewsfinal package and

report

Generate anObjection Memo

based ondiscussion with

objectingCommissioners’

offices

Conduct on OGCpre-agenda

briefing meeting

General Counselreviews finalpackage andreport (when

required)

Close case

Does Asst.GC

approve?

Present atCommission

executive session

Take no furtheraction (TNFA)

Notify respondentand conductinvestigation

A

D

B

no

Does Assoc.GC

approve?

B

no

Does GCapprove?

B

no

yes yes

DoCommission-ers approve

(by tallyvote)?

yes

DoCommissioners vote for

RTB?

no

DoCommission

ers findRTB?

yes

yes

Offerconciliationagreement?

yes

C no

5.3.3SOR

Input into systemNotify all

respondents andcomplainant

Send file to FOIA

yes

OGC 13

1/15/99



C

Investigate caseand gather

additional data (ifnecessary)

Resolvediscovery

disputes (wherenecessary)

Respondentrequests or OGCrecommends pre-probable cause

Generate andcirculate report

Send proposedConciliationAgreement

Generate andcirculate an

Objection Memobased on

discussion withobjecting

Commissioners’offices


report


report

Tally vote toapprove?

E

D G

F

Conduct pre-agenda briefing

meeting

Commissionershold an executive

session

DoCommissioners approvepre-probable

cause?

yes

yesE, L

no

Close caseInput into systemNotify all


Send file to FOIA

DefensiveLitigation


F

Does Asst.GC

approve?


reviewsyes

G

no

Does Assoc.GC

approve?

G

no

General Counselreviews

Does GCapprove?

DoCommission-ers approve

(by tallyvote)?

yes

Gno

H

M

no

yes, if notsigned

OGC 14

1/15/99



H




offices

Conduct OGCpre-agenda

briefing meeting

Participate inCommissioners’

ExecutiveSession on

counter-proposedpre-probable

cause agreement


approveagreement?

Attain signaturefrom respondents

Circulateagreement to

Commissionersfor acceptance

Close case as tothat respondent

yes

Send torespondent

Commissioner-revised proposal

no

Doesrespondent

acceptrevised

agreement?

Draft reportrecommendingacceptance or

rejection ofcounter proposal

Fyes

Continueinvestigation

stageE

Mid or postinvestigationprosecuterial

directiondismissal2

Draft GeneralCounsel’s brief

(probable causeto believe or no

PCB)

no

L


brief

Does Asst.GC approve

brief?

Assoc. GeneralCounsel reviews

briefyes

no

Does Assoc.GC approve

brief?

General Counselreviews brief

yes

L

no

L

no

Does GCapproves

brief?

Send respondentProbable Cause

Brief and send toCommissioners

for their files

yesL noReceive

respondent ReplyBrief

Draft reportrecommendingprobable causeor no probablecause and aconciliation

agreement forprobable cause


report

Does Asst.GC approve

report?

Assoc. GeneralCounsel reviews

reportyes I

N

no

N

2 This may involve report generation, approval, circulation to Commissioners processes

OGC 15

1/15/99



IDoes Assoc.GC approve

report?

General Counselreviews report

yes

N

no

Does Assoc.GC approve

report?yes

N

no

DoCommissioners approverecommendation andagreement

by tallyvote?

If do not approveeither the report

or the agreement

If approve bothreport andagreement

If do not approveprobable cause

recommendation

K

Close caseNotify

complainant andrespondents




offices

Conduct on OGCpre-agenda

briefing meeting

Present atCommission

executive session

OGC 16

1/15/99



J

Commission-ers vote for

probablecause

Send proposedconciliation

agreement torespondents

yes

K D

Negotiatecounterproposedagreement (oral

and written)

Draft reportrecommendingacceptance or

rejection ofcounterproposal

G

Attain signaturefrom respondents

Circulate toCommissioners

Commission-ers tallyvote on

acceptance

Lyes

Commissionerssend back to

OGC for moreinvestigation

Commissionersvote for no

probable causeor PCTB/no

further action

Commissionersvote to close file

or split on its voteand OGC closes

file

Refer toDepartment to

Justice

E

Close case

5.3.3SOR

when applicable


respondents andcomplainants

Send file to FOIA5.3.3

DefensiveLitigation

Generate andcirculate an

Objection Memobased on

discussion withobjecting

Commissioners’offices


briefing meeting

Commissionershold an Executive

Session

Commission-ers acceptagreement?

E

L

no

no

yes

yes3

3 Only if last respondent in case

OGC 17

1/15/99



LClose case as tothat respondent

When entire filecloses, notify


Close case(paper)


respondents andcomplainants

Send file to FOIAsection

5.3.3DefensiveLitigation

If Probable Cause to Believe Agreement Not Reached...

Recommend toauthorize suit

Recommend toclose file

Draft report

AssistantGeneral Counsel

reviews


reviews

Litigation reviewsGeneral Counselreviews and signs

Schedule onCommissioners’

agendaClose case

Commissionersrequest further

conciliation

Transfer caseand files to

Litigation andoffer to settleprior to suit

Litigate case

DoCommission

-ersauthorize

suit?

yes

no K

Enforcement staffreview settlement

offers

Acceptoffer?

no

yes

OGC 18

1/15/99

5.3.2 Central Enforcement Docket


Internallygenerated

Directive 6

RAD referral

Sue Sponte

Outside agencyreferral

Whereappropriate,

assign pre-MURnumber

Receive externalcomplaint

Review forstatutory criteria

Submit issues tospecial assistant

to review forjurisdiction

Complainantresubmits?

Send copy toCommissionersfor information

Notifycomplainant and

respondents

Assign MURnumber

Create files forCED staff and

leader. Create apermanent file.

Input basic casedata (i.e., statuteareas effected)

Generate list ofrespondents

Prepare synopsisof case and enter

into EPS

Send to CEDleader

Assign paralegal

Review andincorporatechanges as

needed

Open case onEPS and MTS

systems

Conductpreliminary

review of legalissues

Determinewhether an

overlap with Auditexists

Refer to PFESP

Meetcriteria?

yes

no

End

yes

no

A

OGC 19

1/15/99

5.3.2 Central Enforcement Docket


A

Docket generatesand mails

respondentletters

Respondentrequests forextension

Receive allresponses

Rate case onEPS

Complaint generated matters only

Circulate ratingssheet and

responses toCommissioners

Does caserate belowthreshold?

Bno

Hold case in CED

Paralegalpreparesnarrative

summary foreach case

CED Leaderdrafts periodic

GC Reportrecommending

dismissal


reviews

Does Assoc.GC

approve?

General Counselreview

Does GCapprove?

yes

C

E

Do theyapprove ontally vote?

Circulate GCreport to

Commissionersyes

GenerateObjection Memo

based ondiscussions with


offices


briefing meeting

Participate inCommissioners’

ExecutiveSession

no

DoCommission

-ersapprove?

Notifycomplainants and

respondentsyes

yes

E

no

Transfer files toFOIA section

Close case inEPS and MTS.Enter case inMUR Coding

system

DefensiveLitigation

OGC 20C

yes

1/15/99

5.3.2 Central Enforcement Docket, continued


B

Compilesummary

information onCED cases forCED monthly

meeting

Prepare andcirculatesummary

information andagenda

Receive teamleader reports(case load and

projects)

Solicit teamleader input onstaff availability

for cases

Review casesand workload

Hold CEDmonthly meeting

Activate newcases and assign

them to staffattorneys

Team leadersidentify staffavailability

Leave case inCED

Create EPSStatus Report(Informational)

Is caseactivated?

AssociateGC

approvesreport?

Place onCommission’s

agenda forreview1

End

CED paralegalsupdate systems

CED paralegalpull case files and

master file

Conduct a page-by-page

comparison tomaster file

Return master fileand send othercopies to team

leader, staffattorney andinvestigator

no

yes

yes

yes

1 Commissioners can decide not topursue the cases

OGC 21

1/15/99

5.3.3 Statements of Reason


Commissionersfail to approve

GeneralCounsel’s

recommendationto go forward

(vote against orsplit vote)

Write draftStatement ofReasons and

cover memo ifmajority vote;

write cover memoonly if a split vote

Assistant generalcounsel reviews

DoesAssistant

GCapprove?

Associate generalcounsel reviews

Does AGCapprove?

yesGeneral Counsel

reviewsDoes AGCapprove?

Send toCommission

Commissionissues final

Statement ofReasons

Return Statementof Reasons toOGC for files

Send Statementof Reason tocomplainant

when case closes

OGC 22

1/15/99

5.3.4 Dismissing Low Rated and Stale Cases


Identify case forclosing

Generate reportrecommending

closing

CED Leaderreviews

Does CEDLeader

approve?

Associate generalcounsel reviews

Does AGCapprove?

yesGeneral Counsel

reviewsyes

Does GCapprove?

Commissionconducts a tally

vote on individualcases

Close caseClose case

(paper)yes

yes

Close case?

Return to CED

no



Send file to FOIA

OGC 23

1/15/99

5.3.5 Maintaining the Permanent File


Receivedocument relating

to a MUR

Match documentwith MUR

Determine towhom the case is

assigned

Generate fourcopies

Return original tomaster file anddistribute other

copies

5.3.6 Coordinating Executive Session Agenda

CED receivesreport forcirculation

Forward report toCommission

SecretaryObjection?

Distribute votesheets showing

objections

Prepare draftagenda

Circulate draftagenda forcomment

Distributecertification of

Commission vote

Revise asnecessary

Send finalagenda to

CommissionSecretary

yes

no

OGC 24

1/15/99

5.3.7 Tracking Civil Penalties


Receive copy ofcheck from

Administration

Update CivilPenalty Tracking

database

Generate two-way memo toAdministration

regardingdisposition of

check

Distribute copiesof two-way memo

and check

5.3.8 Archiving

Hold closed casefile for specifiedperiod of time

Collect and stagefiles for

retirement inNational Archives

Send indices toAdministration toschedule pick-up

Provideaccessionnumbers to

docket

Add accessionnumbers to labels

and seal boxes

Package, indexand label boxes

Send toAdministration to

ship

OGC 25

1/15/99



6.0 Office of Planning and Management(OPM)

Process Customers

Internal: All FEC offices

External: Congress, OMB


Within the Office of Planning and Management, fourprocesses were mapped.

6.1 Budget Formulation process begins with a meetingbetween the Staff Director, Data Systems, and the FinanceCommittee to formulate the basic tenor and policy ofbudget. Then in April or May, the Planning andManagement Director, Staff Director, and Deputy StaffDirector develop guidance for managers and provide themanagers with the guidance and accompanying schedule. InJune, the Division Managers prepare individual budgets andmemos for the Planning and Management Division. In earlyJuly, the Planning and Management Director uses these datato prepare draft budget. The Finance Committee andDivision Managers review the draft budget in mid-July, andDivision Managers prepare memos for Planning andManagement Division. From the feedback, the Planning andManagement Director prepares a revised budget.

In early August, the Staff Director and Deputy Staff Directorreview and approve the budget. The Finance Committeeagain reviews the budget and offers revision suggestions tothe Planning and Management Director, who revises thebudget as indicated. During the month of August, theDivision Managers review, and the Finance Committeeapproves, the revised budget. In September, the FEC submitsthe budget to the Office of Management and Budget (OMB)and to Congress for approval. In November, Planning andManagement negotiates and reaches an agreement withOMB on passback. In November/December, the Planningand Management Director and the Finance Committeeamend the FEC request based on the OMB passback, andthe Planning and Management Director prepares testimonythroughout January. Between January and February, thePlanning and Management Director prepares justification forCongress. The Division Managers and the FinanceCommittee review and approve the justification.

In June and July, the Planning and Management Directorreallocates funds as necessary to account for cost-of-livingadjustment (COLA) changes, grade and step changes, etc. InJuly, the Planning and Management Director develops themanagement plan and provides schedule and guidance tothe managers. In August/September, the Finance Committeereviews and approves the management plan, and byOctober, the Commission reviews and agrees on themanagement plan.



6.2 Budget Management process begins in June or Julywhen the Planning and Management Director reallocatesfunds as necessary, accounting for cost-of-living changes,grade and step changes, etc. In July he or she develops themanagement plan and provides the schedule and guidanceto managers. The division managers then prepare memos forOPM. During August and September, the FinanceCommittee reviews and approves the management plan andforwards it to the Commission for review. By October, theCommission reviews and approves the plan.

Category A: Quarterly Adjustments begins when thePlanning and Management Director prepares and distributesmonthly MIS reports. To prepare this report, he incorporatesMIS data, the monthly budget execution report, accountingsystem data, and Reports Status System data. Then, everyquarter, Accounting makes monthly reallocations, and thePlanning and Management Director prepares a quarterlyadjustment request. If the request is less than $500,000, thenthe Finance Committee and the Commission review andapprove the request. If the request is more than $500,000,the Finance Committee and the Commission review andapprove the request, and the Appropriations Committeerequests reprogramming.

Category B: Earmarked Funding Reallocation begins whenthe FEC prepares a request to the Appropriations Committeeto reallocate funds from Category B to Category A. TheAppropriations Committee reviews and approves the request

to move funds. This process is very rare; it has only occurredonce.

6.3 Monthly Budget Reporting begins when the Planningand Management Director prepares a monthly report ofobligations versus budgeted expenditures and sends thereport to the Budget Officer and Staff Director for review.The Planning and Management Director incorporates theBudget Officer and Staff Director’s comments into the reportand distributes it to FEC offices for review. The Directorrevises the report based on these comments.

6.4 Developing FY 2000 Performance Plan begins when theDirector of Planning and Management develops a draft ofthe FY 2000 Performance Plan and sends the draft plan tostaff for review. The staff reviews the draft plan and returns itwith comments. OPM revises the plan based on thecomments and sends the revised plan to the FinanceCommittee for review. OPM revises the plan, incorporatingthe Finance Committee comments, and returns the revisedplan to the Finance Committee for review and approval.Once approved, the final plan is forwarded to theCommission for review and approval. Once approved, FECforwards the plan to the Office of Management and Budgetand Congress.

Develop strategicplan

Develop guidancefor managers,

Provide schedule/guidance tomanagers

Prepare individualbudgets and

memos for P&M

Use data toprepare budget

Review budgetand amend andprepare memos

for P&M

Prepare revisedbudget

Review budgetand approve

Review budgetand makerevisions

Revise budget asindicated

6.1 Budget Formulation(timing indicated is for a "normal" year)

Planning and ManagementDirector, Staff Director, Deputy

Staff DirectorPlanning and Management

Director Division Managers

Planning and ManagementDirector, Staff Director, Deputy

Staff DirectorPlanning and Management

Director

Division ManagersPlanning and

Management DirectorStaff Director,

Deputy Staff DirectorFinance Committee

Planning andManagement Director

Review revisedbudget

Approve revisedbudget

Submit budget toOMB andCongress

Division Managers Finance Committee

Developed every5 - 6 years

April/May May June Early July

Review budget

Finance Committee

Mid-July July July Early August Mid-August

Mid-August August August September

FEC

Amend requestbased on OMB

pass back

November/December

Planning and ManagementDirector/Finance Committee

Reach agreementwith OMB

PrepareJustification for

Congress

Review andapprove

Justification

Review andapprove

Justification

January/February

January/February

January/February

January/February

Prepare testimony


December/January

FECPlanning and

Management DirectorFinance CommitteeDivision Managers

1/15/99

6.0 Office of Planning and Management OPM 1

Reallocate fundsas necessary

Developmanagement plan

Provide schedule/guidance tomanagers

6.2 Budget Management Process(timeframe assumes a "normal" year)

Planning and ManagementDirector


(account for COLA changes,grade & step changes etc.)

Prepare anddistribute monthly

MIS report

Make monthlyreallocations

Prepare quarterlyadjustment

request


Accounting

Use- MIS data- Monthly budget execution report (Accounting)- Accounting system data- Reports Status System data

Category A: Quarterly adjustments


Review andapprove request

Finance Committee

Is the requestunder

$500,000?yes


Request re-programming

FinanceCommittee

noAppropriations

Committee

Prepare request toreallocate funds

from Category B toCategory A

Review andapprove request to

move funds

FECAppropriationsCommittee

Category B: Earmarked funding reallocation*

June/July July July

Prepare memosfor P&M

Review andapprove

management plan

Review and passmanagement plan

July August/September

by October

Division ManagersFinance

Committee Commission

Monthly Every Quarter Quarterly or as needed


Commission


Commission

(May require input fromDepartment Managers)

* very rare: only happened once

6.0 Office of Planning and Management


1/15/99

OPM 2

6.3 Monthly Budget Reporting

Prepare monthlyreport of

obligations versusbudgeted

expenditures

Send report toBudget Officer andStaff Director for

review

Revise reportDistribute report to

offices

Revise reportbased on

comments

6.0 Office of Planning and Management

6.4 Developing FY 2000 Performance Plan

Develop FY 2000Performance Plan

Send plan to staff Staff reviews planSend comments to

Planning andManagement

Revise planSend plan to

FinanceCommittee

FinanceCommittee

reviews plan

Develop final planForward final plan

to FinanceCommittee

FinanceCommittee

reviews final plan

FinanceCommittee

approves final plan

Forward final planto Commission

Commissionreviews and

approves final plan

Forward approvedplan to OMB and

Congress

1/15/99

OPM 3



7.0 Administration

Process Customers

Internal: All FEC offices

External: Department of Treasury


Within the Administration, five processes were mapped.

7.1 Accounts Payable process begins when an accountingtechnician inputs vendor data into vendor file. These datainclude vendor name, address, account number, and routingnumber. The vendor file feeds into the payment system.Then weekly, an administrative assistant reviews systemchanges and notifies the accounting officer of securityviolations.

7.2 Procurement process begins when an FEC employeeprepares a Purchase Requisition Form (PRF) and receives hisor her manager’s approval for the purchase. The employeesends the PRF to the Budget Officer, who reviews it forreasonableness and to ensure that the request is withinbudget guidelines. Then Administration reviews andapproves the requisition, assigns it a cost code, prepares apurchase order (PO), and manually distributes eight copies.At this point, the process splits: the 7.3 Vouchering process

begins, and the receiving unit fills the order, accepts thegoods, matches the PO to the packing slip, completes andforwards the Receiving Report to Accounting, and files thePO and Receiving Report.

7.3 Vouchering begins when Administration files theinvoice, PO, and Receiving Report seven days prior to thepayment due date and sorts payments into batchesaccording to type of electronic payment.

For electronic fund transfer payments, an accounts payabletechnician inputs into the accounting system the paymentdata, including amount, date, schedule, and DAC. Then thetechnician runs a program to create information on a floppydisk. An accounting officer logs onto the Treasury Paymentsystem, and an accounts payable technician loads paymentinformation from floppy disk onto system. A certifying officerverifies and certifies payment information and forwards thepayment document to the Accounting Director. Theaccounts payable technician files invoices, PO, andReceiving Report in Paid file. Treasury reviews payment dataand transfers funds into the vendor’s bank.

For check payments, an accounts payable technician enterscheck payment information into OBL− 12 and prints screen.A different technician copies payment information onto afloppy disk. An accounting officer logs onto the TreasuryPayment system, and the technician loads the paymentinformation from the floppy disk onto the system. The



certifying officer verifies and certifies payment informationand forwards invoices to Accounting, where they are filedalong with the PO and Receiving Report, in the Paid file.Treasury reviews payment data, issues checks, and mails thecheck to the vendors.

7.4 Monthly Reconciliation begins when Administrationprints the reconciliation report from the Armour system andreconciles the report with the General Ledger trial balanceand Treasury’s bank statement. In addition, Administrationreviews the account status and notifies account holder oflow balances or of the option of closing his or her account.

7.5 Cash Receipt System has three subprocesses. 7.5.1 CashReceipt System – Daily Operations begins when a salestransaction in Public Records occurs. Sales can be paid forby cash, check or credit card or by using a prepaid customeraccount. Public Records runs a daily batch report of dailytransactions and reconciles the batch report with the cashand receipts in cash drawer. Once reconciled, PublicRecords takes the report, cash, and receipts to Accounting.Accounting reviews the report, counts the cash and receipts,and provides Public Records with a receipt. In addition,Accounting inputs the receipt data into the Accountingsystem and deposits the money into Treasury’s bank accountvia courier service.

7.5.2 Cash Receipt System – Opening a Customer Accountbegins when a customer completes the paperwork and

makes a payment, which is entered into the Armour system.The payment is considered a daily transaction, and thisprocess feeds into 7.5.1 Daily Operations process.

7.5.3 Cash Receipt System – Replenishing a CustomerAccount begins when the Mailroom receives and routespayment to Accounting, which sends it to Public Records.Accounting prepares remittance and forwards to PublicRecords, which holds the receipts in a safe, enters themdaily into the Armour system, and deposits them twice aweek into Treasury’s bank account via courier service. Thepayment is considered a daily transaction, and this processfeeds into 7.5.1 Daily Operations process.

7.1 Accounts Payable

1/15/99

7.0 Administration

Input vendor data1

into vendor file(feeds payment

system)

Review systemchanges weekly

and notifyAccounting Officer

of securityviolations

AccountingTechnician 1

Administrative Assistant

1 Input name, address, account number, routing number

7.2 Procurement

Prepare PurchaseRequisition form

(PRF)Receive approval

Review PRF forreasonablenessand to ensurewithin budget

guidelines

Approverequisition and

assign cost code

Manually distributeeight PO copies

Prepare PurchaseOrder (PO)

Fill order

Accept goods andmatch PO topacking slip

Completereceiving reportand forward to

Accounting

File PO andreceiving report

Receiving UnitReceiving Unit

Budget Officer Administration Administration Administration Receiving Unit

Receiving Unit

FEC Employee Manager/Supervisor

7.3Voucherin

g

ADM 1

7.3 Vouchering

7.0 Administration

1/15/99

File invoice, POand Receiving

Report seven daysprior to prompt

payment due date

Sort payments intobatches according

to type ofElectronic

Payment (ECS)

Input paymentdata amount, date,schedule and DAC

into accountingsystem

Run program tocreate information

on floppy disk

Log onto TreasuryPayment system

Load paymentinformation from

floppy disk

Verify and certifypayment

information

Forward paymentdocument toAccounting

Director

File invoices, POand Receiving

Report in Paid file

Review paymentdata and transferfunds to vendor

bank

Verify and certifypayment

information

Forward invoicesto Accounting

Log onto TreasuryPayment system

Load paymentinformation from

floppy disk

Enter checkpayment

information intoOBL-12 and print

screen

Copy paymentinformation onto

floppy disk

Review paymentdata, issue checks

and mail tovendors

File invoices, POand Receiving

Report in Paid file

For check payments:

AP Technician AP Technician 2 Accounting Officer AP Technician Certifying Officer Certifying Officer

Treasury

AP Technician

AP Technician Treasury

Certifying OfficerAP TechnicianAccounting Officer Certifying OfficerAP Technician 2AP Technician 2

For electronic fund transfer payments:

ADM 2

7.4 Monthly Reconciliation

Print reconciliationreport from

Armour system

Agreereconciliation

report to GeneralLedger trial

balance

Agree to TreasuryDepartment’s bank

statement

Review accountstatus

Notify accountholder of low

balances or of theoption of closing

account

7.0 Administration

7.5.1 Cash Receipt System Daily Operations

Sales transactionat Public Record’scash register intoArmour system

Run daily batchreport of dailytransactions

Reconcile betweenbatch report andcash/receipts in

cash drawer

Take report, cashand receipts to

Accounting

Review report andcount cash and

receipts

Input intoAccounting system

Give receipt toPublic Records

Deposit intoTreasury bank

account via courierservice

1/15/99

Sales can either bepaid by cash, check,

credit card, or by usinga prepaid customer

account

A

7.5 Cash Receipt System

7.5.1 DailyOperations

7.5.2 Opening aCustomer Account

7.5.3 Replenishinga Customer

Account

ADM 3

7.5.2 Cash Receipt System - Opening a Customer Account

Completepaperwork

Make paymentInput into Armour

system

7.0 Administration

7.5.3 Cash Receipt System - Replenishing a Customer Account

Prepareremittance and

forward to PublicRecords

Holds receipts insafe

Deposit everyTuesday andThursday into

TreasuryDepartment’s bankvia courier service

1/15/99

A

A

Mailroom receivesand routespayment toAccounting

Public Recordsrecords dailyreceipts onto

Armour system

Public Recordsreceives payment

ADM 4